This case involved the renewal copyrights to the songs by singer/songwriter Roger Miller who assigned his copyrights, original and renewal, to Sony's predecessor-in-interest.
Sony filed applications to register the renewal copyrights in Miller's songs in January and April 1992 and the copyrights were subsequently registered. Miller, however, died on October 25, 1992, and in his will, he granted all his intellectual property interests to his wife who in turn assigned those interests to Roger Miller Music, Inc.
The basic issue before the Sixth Circuit was whether Sony owned the renewal copyrights when Miller was still living at the time Sony, his assignee, applied to register those copyrights but died before the actual start of the renewal term.
Looking to the statutory language of the Copyright Act, which states in part that the renewal copyright vests in any party entitled to it "at the time the application is made," and legislative history, the Sixth Circuit concluded that Sony, as assignee of the author, secured an interest in the renewal copyrights because Miller was alive at the time Sony applied for renewal. That Miller subsequently died before the beginning of the renewal term did not divest Sony of its ownership of the renewal copyrights.
The case cite is Roger Miller Music, Inc. v. Sony/ATV Publishing, LLC, No. 10-5363 (6th Cir. Feb. 22, 2012).