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16 Fordham Intell. Prop. Media & Ent. L.J. 61 (2005-2006)
Unforced Rhythms of Grace: Freeing Houses of Worship from the Specter of Copyright Infringement Liability

handle is hein.journals/frdipm16 and id is 71 raw text is: Unforced Rhythms of Grace: Freeing
Houses of Worship from the Specter of
Copyright Infringement Liability
Brian D. Wassom*
INTRODUCTION     ..........................................................................  67
I. LEGAL BACKGROUND: THE HISTORY AND CURRENT STATE OF
COPYRIGHT LAW AS IT PERTAINS TO THE USEOOF
COPYRIGHTED WORKS IN RELIGIOUS SERVICES ................... 72
A. COPYRIGHT BASICS. AN OVERVIEW ................................. 72
B. BACKSTORY. THE EVOLUTION OF COPYRIGHT LA wFROM
1787-1909   .....................................................................  75
C. ADJUDICATION OF WORSHIP-RELA TED USES OF COPYRIGHTED
WORKS UNDER THE 1909 COPYRIGHTACT ....................... 79
1. W  ihtol v. Crow   .......................................................... 79
2. Robert Stigwood Group Ltd. v. O'Reilly ................. 82
3. F.E.L. Publications, Ltd. v. Catholic
Bishop  of Chicago   ...................................................  84
4. Summary of Worship-Related Holdings under the
1909  A ct ...................................................................  88
D. THE CURRENT COPYRIGHT
Partner, Honigman Miller Schwartz and Cohn LLP, Detroit, Michigan; Law Clerk to
the Hon. Alice M. Batchelder, U.S. Court of Appeals for the Sixth Circuit, 1999-2000;
J.D. magna cum laude, 1999, Case Western Reserve University School of Law. I
dedicate this Article to my sister, Karey Sue Hartford. The commitment and good humor
that she displays in her professional and academic endeavors and family life fill me with
inspiration and pride. I was privileged to receive sage advice concerning drafts of this
Article from several wise counselors, including David Nimmer, Esq., Prof. Jonathan
Entin, and Prof. Thomas Berg. I also thank Colin Harfield for sharing his practical
insight, Henri 0. Harmon, Kimberly Koscielniak, Sarah Wohlford, and Keli McLoyd for
their research and editorial assistance, and Peggy Binder for her secretarial labors. All
remaining errors in logic and expression are my own.

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