The First Circuit held yesterday that a "reconstruction" of a copyrightable work doesn’t satisfy the "copy" requirement for copyright registration. The author in the case wrote down lyrics and music for an original song on a piece of paper in 1993. He forgot about it until eight years later, when he learned that somebody else had recorded it. He then applied to register his copyright in the song with the U.S. Copyright Office. But, after the songwriter won a verdict of infringement, the district court dismissed the case for want of subject matter jurisdiction. The First Circuit affirmed, concluding that a reconstruction from memory violates the jurisdictional prerequisite of depositing a "copy" of the work with the registration application. Torres-Negron v. J & N Records, LLC, Nos. 06-2058 & 06-2059 (1st Cir. Oct. 2, 2007).