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 even though neither Anna nor Savoy signed a licensing agreement with the SDO. 293 F.3d at 794, 803. Thus, the issue in cases involving governmental adoption of model codes “is not the voluntariness of the appropriation but the legal consequences flowing from the permission that [the SDO] gave.” Id.

The Solicitor General similarly noted that the concerns raised in CCC would be inapposite in model building code cases “because [the SDO] invited the towns to enact its building code and therefore would presumably not have a valid takings claim.” Solicitor General’s Brief at 12 n.4. Claims regarding the Copyright Act are equally inapposite, as 17 U.S.C. Sectionsection [sic] 201(e) applies only to copyrights held by individual rather than corporate authors and more fundamentally “addresses government actions avowedly intended to coerce a copyright holder to part with his copyright, so that the government itself may exercise ownership of the rights.” Id. at 16 & n.7. Because Anna and Savoy adopted the model codes into law at SBCCI’s invitation, their actions clearly were not the type of coercive seizure contemplated by the statute.

ICC undisputedly encourages the adoption of its model codes into law as a general matter, which counsels against