Instructions for the Continuation form
After filling out Form VA, please follow these instructions for filling out Form GR/PPh/CON. (Our annotated sample form has some hints.) Or, see below for a discussion of some alternatives.
Section A
Fill in your full name on both lines.
Section B
Fill in a title for each image submitted, along with its date of first publication, the country of publication and an optional description for each photograph.
Note that, as of March 2005, you may attach no more than 50 continuation forms to one Form VA. Each continuation form lets you identify up to 15 images. Thus, you can register up to 750 images per group. If you have more than that, you may
divide them into batches of 750 (or fewer) images and submit each batch with its own Form VA, or
register without using continuation forms, which are not mandatory. See below for a discussion of the alternatives.
Section C
Fill in your name and mailing address.
Include Form GR/PPH/CON together with Form VA, a check for the registration fee and your image deposit, and send it to the Copyright Office. Of course, you should keep a backup copy of everything, just in case.
Alternatives to using continuation forms
Initially, the Copyright Office had no limit on the number of continuation forms you could attach to a single form VA. However, it became apparent that there were practical limitations imposed by the sheer volume of paper in a really large group registration. Hence the decision to limit the number of attached forms to 50.
Fortunately, there are alternative ways of registering a large group that do not use the continuation form. As explained in the Copyright Office’s formal regulation on the subject, you may instead:
Submit a group of photographs published within three months before receipt in the Copyright Office and give the range of dates within that period on the application for registration at space 3b; or
Submit a group of photographs published within a calendar year, give the range of dates within that period on the application for registration at space 3b, and identify with each deposited image the date of its publication.
The regulation goes on to clarify that, if you elect not to use continuation sheets, the date of publication may be provided in any of three different ways:
- directly on each deposited image,
- in a text file on the CD-ROM or DVD that contains the deposited photographic images, or
- on a list that accompanies the deposit.
Dates of publication must be provided in a way that clearly identifies the date of publication for each individual photograph in the group.
Pros and cons
Some legal experts believe that, if you end up in court, your position could be slightly stronger if you have used continuation sheets. The registration certificate, of which the continuation sheets are a part, serves as prima facie evidence of the date of publication of a work when it is registered within five years of first publication.
On the other hand, if you make thousands of images and register them all (as ASMP encourages you to do), the filing fees and extra postage can add up. Registering without continuation sheets is far, far better than not registering, and you can register any number of images for a single filing fee.
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