GRUW: Eligibility, Deposit Files, Fees, and Refusals

Group Registration of Unpublished Works, or GRUW, lets you register between two and ten unpublished works on a single electronic application through the Copyright Office’s eCO system for one $85 filing fee. Every work has to share the same author and claimant and fall within the same administrative class. Used correctly, it replaces up to ten separate filings with one.

When GRUW Is the Right Option

You already own the copyright in anything original you create and fix in tangible form. Registration is what gives that ownership teeth. For unpublished works the timing is unforgiving: statutory damages and attorney’s fees are only available if you registered before the infringement began, and there is no three-month grace period like the one that applies to published works.1Office of the Law Revision Counsel. 17 USC 412 – Registration as Prerequisite to Certain Remedies for Infringement If your manuscript is copied on Tuesday and you register on Wednesday, those remedies are already off the table for that infringement. You also cannot file an infringement suit in federal court over a U.S. work until you have a registration or a refusal in hand.2Office of the Law Revision Counsel. 17 USC 411 – Registration and Civil Infringement Actions

GRUW is the cheapest way to cover a batch of unreleased material before any of that becomes a problem.

Who and What Qualifies

The rules come from 37 C.F.R. ยง 202.4(c), and the Copyright Office enforces them strictly. If any single work in your group fails one of them, the Office can refuse the entire registration. There is no option to drop the problem work and approve the rest.

Every work must be unpublished at the time you submit. “Unpublished” means no copies have been distributed to the public and the work has not been offered to a group for further distribution, public performance, or public display.3U.S. Copyright Office. Circular 24 – Group Registration of Unpublished Works Posting a song on a streaming platform or selling prints of a photograph makes those works published and ineligible.

The author and claimant must be the same for every work in the group. If you wrote all ten poems and are claiming them in your own name, you qualify. If a company holds the rights, the company must be both author and claimant across the entire batch.4eCFR. 37 CFR 202.4 – Group Registration – Section: Group Registration of Unpublished Works

Works made for hire are not excluded. The regulation allows works made for hire, anonymous works, and pseudonymous works as long as you identify them as such in the application.4eCFR. 37 CFR 202.4 – Group Registration – Section: Group Registration of Unpublished Works A company registering ten internal training videos created by employees can use GRUW as long as the company is listed as both author and claimant for all of them.

Joint Authors

Joint authors can use GRUW, but the same co-authors must have created every work in the group. Two songwriters who co-wrote four songs together can put those four songs in one application. Solo songs by either of them go in a separate filing. All joint authors must be named as claimants for every work, and the authorship statement describing each person’s contribution has to match across the group.3U.S. Copyright Office. Circular 24 – Group Registration of Unpublished Works

How Many Works, and What Types

Each application covers a minimum of two and a maximum of ten works.5U.S. Copyright Office. Group Registration of Unpublished Works GRUW FAQ One work needs a standard application; more than ten means multiple GRUW filings.

Everything in the group must fall within the same administrative class. The Copyright Office recognizes four classes for GRUW:4eCFR. 37 CFR 202.4 – Group Registration – Section: Group Registration of Unpublished Works

  • Literary Works (TX): novels, poems, articles, software code, and similar text-based works.
  • Performing Arts (PA): musical compositions, scripts, choreography, and other performance works.
  • Visual Arts (VA): photographs, illustrations, paintings, sculptures, and other visual works.
  • Sound Recordings (SR): the recorded performance itself, distinct from the underlying composition.

Classes cannot be mixed. Five photographs and five poems require two applications and two $85 fees.3U.S. Copyright Office. Circular 24 – Group Registration of Unpublished Works The one exception: when you register sound recordings, you can include the musical, literary, or dramatic work embodied in each recording in the same application, as long as the author and claimant are the same for both. Five original recorded songs plus their underlying compositions can go through together.6U.S. Copyright Office. Help – Group Registration of Unpublished Works

Filing the Application

GRUW applications are filed electronically through eCO. There is no paper option.7U.S. Copyright Office. Group Registration for Unpublished Works GRUW Before you log in, have this ready:

  • A group title for the collection, which appears on the certificate.
  • An individual title for each work.
  • Full legal name and contact information for the author or joint authors.
  • A digital deposit file for each work, with the file name matching the title in the application.

Deposit Files

The Copyright Office accepts a specific list of file formats, including PDF, TXT, DOC, JPG, TIF, WAV, and MP3, among others. Each file can be up to 500 MB.8U.S. Copyright Office. eCO Acceptable File Types The deposit has to be complete, meaning the file contains all the copyrightable content you are claiming. For visual works, the submission should reproduce the actual colors and show the entire work in context.9U.S. Copyright Office. Compendium of US Copyright Office Practices Chapter 1500 – Deposits The Office does not specify a minimum resolution or DPI; as long as a registration specialist can perceive the complete work, the file is acceptable.

Fee, Effective Date, and Processing

The filing fee is $85, paid by credit card, debit card, or electronic fund transfer at the payment screen inside eCO.10U.S. Copyright Office. Fees The fee is non-refundable whether or not the Office ultimately approves the registration. After payment, the portal directs you to upload your deposit files and generates a confirmation with a submission number. Hold onto that number for status tracking.

The effective date of your registration is not the day of the confirmation email or the day the certificate issues. It is the day the Copyright Office receives your complete submission (application, deposit, and fee), provided everything is later determined to be acceptable.11Office of the Law Revision Counsel. 17 US Code 410 – Registration of Claim and Issuance of Certificate That date is what determines whether you registered before an infringement.

Processing times vary. For electronic filings with no follow-up needed, the average is about 3.6 months, with individual claims running from roughly 2 months to over 5. If an examiner has to contact you, the average stretches to about 5 months and can pass 8.12U.S. Copyright Office. Registration Processing Times FAQs

If an Examiner Contacts You

An examiner who finds a problem will reach out by email or letter. You have 45 calendar days from the date of that communication to respond.13U.S. Copyright Office. Circular 19 – Deadlines for Replying to Copyright Office Correspondence Miss the deadline and the Office can close your file without finishing the examination. You would have to start over with a new application and a new fee. This is where a lot of registrations quietly die, so watch the email address you used to file.

Publishing a Work After Filing

The unpublished requirement is evaluated at submission, but if you publish one of the works after filing and before the certificate issues, the Office can refuse the entire group registration on examination.15U.S. Copyright Office. Circular 24 – Group Registration of Unpublished Works

Refusals and Corrections

If the Copyright Office refuses your GRUW registration, the refusal letter will explain why. You can challenge it through a two-step appeal. The first request for reconsideration must be postmarked within three months of the date on the refusal notice, be in writing, explain why registration was improperly refused, and include a $350 fee.14U.S. Copyright Office. Fees If that fails, a second request for reconsideration is due within three months of the response, costs $700, and must address the specific reasons the Office upheld the refusal.16U.S. Copyright Office. Compendium of US Copyright Office Practices Chapter 1700 – Administrative Appeals Oral arguments and expedited review are not available at either level. Deadlines that fall on a weekend or federal holiday extend to the next business day.

If a certificate has already issued and you find an error or need to add information, file a supplementary registration through eCO. The electronic supplementary fee is $100.10U.S. Copyright Office. Fees A supplementary registration does not replace the original; it creates an additional record that corrects or amplifies the original certificate.