When looking to protect multiple works at once with a single copyright, creators sometimes look to file a collective work copyright on the works.  However, relying on a collective work copyright can be risky.  For example, in Muench Photography, inc., v. Houghton Mifflin Harcourt Publishing Company and R.R. Donnelley & Sons Company, 95 USPQ2d 1489 (S.D.N.Y. 2010) The Court noted that the registration of a collective work may reach the individual works only when the author of the collective work authored each of the individual works. E.g., Szabo v. Errisson, 68 F.3d 940 (5th Cir.1995) (musician's registration of his collection covered each of his individual songs which comprised the collection); Educ. Testing Servs. v. Katzman, 793 F.2d 533, 539 (3d Cir.1986) ("[T]he fact that the registration was for compilations does not preclude protection for the material therein contributed by the author."); Carell v. Shubert Org., Inc., 104 F. Supp. 2d 236 (S.D.N.Y.2000) (group registration of makeup designs covered individual works, but copyright owner was designer of individual designs within the group); Woods v. Universal City Studios, Inc., 920 F. Supp. 62, 64 (S.D.N.Y.1996) (author who filed registration for collective work was the same author of the individual works that were the subject of the infringement). Accordingly, the Court rejects MPI's interpretation of the Copyright Act.

However, the Court held that a plain reading of § 409 of the Copyright Act mandates that the copyright registrations at issue here contain the names of all the authors of the work. See 17 U.S.C. § 409(2). Because a collective work copyright does not list the names of the authors for each individual work in the collective work the copyright cannot be enforced on the individual work.

          Therefore, copyright applicants looking to protect multiple works in a single filing should either register particular works individually, or register these works as part of a group registration.  If the works as a whole qualify for a group registration, that group registration can cover the individual works themselves.  See Copyright Circular 34  https://copyright.gov/circs/circ34.pdf