The AAP stated that since URAA registrations may create legal
presumptions as to the validity of the copyright and the facts stated
on the registration certificate, the Office should question an
applicant's determination of foreign law issues. Comment 7, at 15. Mr.
Karp asserted that since foreign law questions will arise with respect
to many issues related to rights restored, including initial ownership,
the Office should accept multiple NIEs or registrations for the same
work. Comment 8, at 2.

The Copyright Office will accept such multiple, and possibly
adverse, NIEs and registrations for the same work. One of the more
difficult issues facing the Office is to what extent foreign law issues
should be raised in the registration process. Section 104A(b) of the
Act provides: ``A restored work vests initially in the author or
initial rightholder of the work as determined by the law of the source
country of the work.'' Determining the appropriate source country and
the applicable foreign law is a question that must ultimately be
resolved by a court. At most, the Office could simply question whether
or not an author was in fact the author under the law of the source
country. The applicant's answer would have to be accepted. The Office
does not, therefore, plan to question an applicant's determination of
foreign law issues.

IV. Procedures for Notices of Intent To Enforce

A Copyright Office task force has been meeting for several months
to discuss issues related to establishing regulations for URAA filings.
The Office also carefully considered the comments made at the public
meeting and those submitted by interested parties in response to the
Notice of Policy Decision and Public Meeting and the Notice of Proposed