Copyright Registration After Fourth Estate

In Fourth Estate Public Benefit Corporation v. Wall-Street.com, a unanimous U.S. Supreme Court held in March of this year that a copyright claimant can only commence an infringement suit, unless a limited exception applies, after the Copyright Office has taken action and registered a copyright under 17 U.S.C. § 411(a). That section of the statute states "no civil action for infringement of the copyright in any United States work shall be instituted until preregistration or registration of the copyright claim has been made in accordance with this title." Despite this language, different courts around the country, like the parties in this dispute, interpreted this language to mean different things.