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`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`Civil Action No. 24-cv-2406
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`Presiding Judge: Hon. Sara L. Ellis
`Magistrate Judge: Hon. Young B. Kim
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`DELTA TECHNOLOGY
`DEVELOPMENT LLC,
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`Plaintiff,
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`v.
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`THE INDIVIDUALS, CORPORATIONS,
`LIMITED LIABILITY COMPANIES,
`PARTNERSHIPS, AND
`UNINCORPORATED ASSOCIATIONS
`IDENTIFIED ON SCHEDULE A TO THE
`COMPLAINT,
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` Defendants.
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`PLAINTIFF’S MOTION FOR LEAVE TO FILE SUPPLEMTARY REGISTRATION
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`Plaintiff seeks this Court’s authorization to file the copyright registration certificate,
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`marked as Exhibit 4, that reflects the correct year of creation of the copyright, which is 2022.
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`As explained in Plaintiff’s response in opposition to Defendants’ motion to vacate the
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`preliminary injunction, [ECF Dkt. # 41, at 5], Plaintiff did in fact create the works in 2022, and
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`simply made an error in its application to the Copyright Office. Plaintiff was not aware of the
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`inaccurate information when it applied for the copyright registration. The inaccuracy of the
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`information is a simple human error that would not have caused the Register of the Copyrights to
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`refuse registration. The underlying error does not invalidate or otherwise affect the rights or
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`privileges granted by the Copyright and is specifically allowed for correction by the Copyright
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`Office:
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`A supplementary registration is a special type of registration that may be used “to correct
`an error in a copyright registration or to amplify the information given in a registration.”
`17 U.S.C. § 408(d).
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`Case: 1:24-cv-02406 Document #: 43 Filed: 08/06/24 Page 2 of 2 PageID #:279
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`See Compendium of U.S. Copyright Office Practices, Chapter 1800, Section 1802.
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`Accordingly, Plaintiff filed a correction with the Copyright Office and received the
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`supplementary registration with the corrected year of creation.
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`Date: August 6, 2024
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`Respectfully submitted,
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`By: /s/ Shengmao Mu
`Shengmao (Sam) Mu, NY #5707021
`WHITEWOOD LAW PLLC
`57 West 57th Street, 3rd and 4th Floors
`New York, NY 10019
`Telephone: (917) 858-8018
`Email: smu@whitewoodlaw.com
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`Counsel for Plaintiff
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