In an unexpected shake-up within the U.S. Copyright Office, former Register of Copyrights Shira Perlmutter was dismissed from her role, prompting widespread debate about the implications for copyright owners. While political interpretations of her removal vary, one undeniable consequence Ludwig APC is keeping a keen eye on is the issuance of unsigned copyright certificates, raising concerns over their validity and enforceability.
The Dismissal
Perlmutter was appointed Register of Copyrights in 2020. Under her tenure, she oversaw significant policy developments affecting copyright law, including updates on AI-generated content and digital rights management. Her dismissal in May 2025, allegedly due to administrative disagreements, sent shockwaves through the intellectual property (IP) community.
The American Library Association (ALA) reacted strongly, labeling her removal as “unlawful” and warning of disruptions to copyright administration. Publishers Weekly also reported that Perlmutter sought legal action, filing for a judicial restraining order to contest her termination, though the request was denied.
How the Dismissal Affects Copyright Certificates
Following Perlmutter’s departure, the Copyright Office underwent leadership changes that disrupted normal operational procedures. Reports emerged that newly issued copyright registration certificates lacked signatures, a deviation from previous protocol.
Her dismissal leaves no official signatory for registration certificates, which raise questions about the legal weight of unsigned certificates and whether they can serve as valid proof of copyright ownership in litigation.
Further, according to Section 410(a) of the Copyright Act, only the Register of Copyrights is responsible for determining copyrightability and issuing certificates under the Copyright Office seal. Since the law’s wording suggests that the Register alone has the authority to finalize registrations, experts are questioning whether certificates issued during this leadership dispute are legally valid.
Implications for Copyright Owners
For authors, musicians, designers, and other copyright holders, the absence of signatures could pose a serious risk in copyright disputes and enforcement. Typically, a certificate bearing an official signature helps establish ownership and copyright validity in court. Without it, the document’s credibility may be challenged, potentially weakening the copyright holder’s legal position.
Some key concerns include:
- Challenges in proving ownership—If a certificate is unsigned, opposing parties may argue that the registration is incomplete or invalid.
- Increased litigation hurdles—Courts often rely on signed certificates as primary evidence. Without them, plaintiffs might have to provide alternative proof of ownership.
- Uncertain precedent—This is an unprecedented situation, which means future court rulings will determine how unsigned certificates are treated.
How Ludwig APC Sees It
Given the uncertainty surrounding unsigned copyright registrations, Ludwig AP is closely monitoring the situation and preparing strategies to safeguard copyright owner rights. Here is some of what we’re seeing:
1. Legal Challenges to Unsigned Certificates
Should the validity of unsigned certificates be contested, copyright owners may need to establish their legal standing through supplementary filings, expert testimony, and strategic litigation.
2. Alternative Documentation Strategies
Since standard signed certificates are unavailable, copyright owners may need to build comprehensive copyright ownership records using alternative means, including:
- Timestamped drafts and records proving original creation
- Contracts and licensing agreements that confirm ownership rights
- Digital watermarking and blockchain registration for added security.
3. Preemptive Copyright Protection Measures
Rather than waiting until a copyright dispute arises, copyright owners can strengthen their protection proactively:
- Register works with international copyright authorities (such as WIPO).
- Establish contractual safeguards in licensing agreements.
- Create detailed authorship records that stand up in court.
Let’s Work Together: Global Experience, Personal Focus
Perlmutter’s dismissal has triggered unexpected consequences in the copyright registration process, leaving copyright owners grappling with the implications of unsigned copyright certificates.
While the legal enforceability of these documents remains uncertain, Ludwig AP can work with IP owners concerned about the security of their works to help ensure their rights remain protected despite administrative disruptions in the Copyright Office. Contact Ludwig APC today at (619) 929-0873 or [email protected] to arrange a free consultation to discuss your needs.
