In re Peregrine Entertainment, Ltd.
United States District Court for the Central District of California
116 B.R. 194 (1990)
A predecessor of National Peregrine, Inc. (NPI), whose principal assets were a library of movie copyrights and licenses, obtained financing from Capitol Federal Savings and Loan Association of Denver (Cap Fed) secured by essentially all of NPI's inventory, including its films and contract rights; Cap Fed recorded financing statements in Utah, Colorado, and California, but never with the U.S. Copyright Office. After NPI filed for bankruptcy, NPI, as debtor in possession, sued Cap Fed to establish that its security interest was unperfected for lack of Copyright Office recording, making NPI's own interest superior; the bankruptcy court ruled for Cap Fed, and NPI appealed.
Whether a security interest in a copyright must be recorded in the United States Copyright Office in order to be perfected.