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 Copyright Review Board

United States Copyright Office •

September 12, 2022

David L. Duncan, Esq. Law Offices of David L. Duncan 164 Columbia Heights, No. 4 Brooklyn, NY 11201

Dear Mr. Duncan:

The Review Board of the United States Copyright Office ("Board:) has considered Caroline Caldwell's ("Caldwell") second request for reconsideration of the Registration Program's refusal to register a copyright claim in the work titled "Untitled" ("Work"). After reviewing the application, deposit copy, and relevant correspondence, along with the arguments in the second request for reconsideration, the Board affirms the Registration Program’s denial of registration.

I.DESCRIPTION OF THE WORK

The Work is a 15-word epigram: "In a society that profits from your self doubt, liking yourself is a rebellious act."

II.ADMINISTRATIVE RECORD

On June 11, 2019, Caroline Caldwell filed an application to register a copyright claim in the Work. In an August 14, 2019 letter, a Copyright Office registration specialist refused to register the claim in the epigram, finding that the Work lacked the minimum literary authorship necessary to support a copyright registration. Initial Letter Refusing Registration from U.S. Copyright Office to David Duncan (Aug. 14, 2019).