"In Jefferson Airplane v. Berkeley Systems, Inc., 32 U.S.P.Q. 2d 1632 (N.D. Cal. 1994), the district court deferred to Office registration regulations and practices presented by then-music examiner Marybeth Peters. The court held that a pre-1978 registration for a sound recording does not cover artwork on the album cover. Under practices governing sound recordings registered under the 1909 Act, jacket cover art work had to be registered separately from the sound recording, and the court was unwilling to rule that a Class N registration covered all the copyrightable authorship owned by the plaintiff." page 14, 98th ANNUAL REPORT OF THE REGISTER OF COPYRIGHTS For the fiscal year ending September 30 1995 LIBRARY OF CONGRESS / WASHINGTON, D.C. / 1996
