IP Law Daily, WORTH NOTING—Other IP law developments, (Jan 23, 2026)

By WK Editorial Staff

A periodic roundup of other items of interest to the Intellectual Property community.

COPYRIGHT—S.D.N.Y.: Major record companies—including Atlantic, Elektra, Warner Records, Sony Music Entertainment, Arista, UMG, and Capitol Records, along with Spotify USA—have been granted a preliminary injunction barring Anna’s Archive, an open-source search engine for "shadow libraries," from hosting, linking to, reproducing, streaming, or otherwise exploiting copyrighted works owned by the plaintiffs. The federal district court in New York City determined that the plaintiffs had demonstrated a likelihood of success on their copyright infringement claims, and that they would sustain irreparable harm unless Anna's Archive is restrained and enjoined by the court. Explained the court, “Anna's Archive's continued infringement of copyrighted works owned by the Record Company Plaintiffs … as well as its stated intent to mass release and distribute those sound recordings to the public, would substantially diminish the value of the Record Company Plaintiffs' copyrighted works and interfere with the Record Company Plaintiffs' rights and ability to control their sound recording catalogs, and to license, sell, and distribute their sound recordings.” The court also said that injunctive relief was warranted because losses from Anna's Archive's ongoing violations would be difficult to measure, that Anna's Archive is likely to evade enforcement of any judgment for its infringement, and that Anna's Archive lacks sufficient assets in the United States to satisfy a judgment. The court also ordered all domain name registries and registrars of record for Anna's Archive domain names and all hosting and Internet service providers for Anna's Archive websites to disable access to the relevant domain names and nameservers and to cease all hosting services for Anna’s Archive and related sites (Atlantic Recording Corp. v. Anna's Archive, No. 1:26-cv-00002-JSR (S.D.N.Y. Jan. 20, 2026)).

PATENT—Fed. Cir.: The challenged independent claim of a patent related to a mobile device that is dynamically software configurable for a variety of environments was invalid as obvious, according to the U.S. Court of Appeals for the Federal Circuit. Apple—which challenged the patent owned by Smart Mobile Technologies in an inter partes review—successfully argued that the claim was similar enough to claims from other patents that the Patent Trial and Appeal Board had previously decided were invalid that collateral estoppel should apply. The Board was therefore precluded from determining that the claim at issue was valid (Apple Inc. v. Smart Mobile Technologies LLC, No. 24-1352 (Fed. Cir. Jan. 21, 2026)).

PATENT—Fed. Cir.: The Patent Trial and Appeal Board correctly affirmed, in an ex parte reexamination, a USPTO examiner’s rejection of all 16 claims of a patent related to an invention for monitoring and controlling an HVAC system to determine whether it is on or off, the U.S. Court of Appeals for the Federal Circuit has held. The Board properly sustained the Examiner’s rejections of the claims for improper enlargement. During reexamination, the patentee amended the last limitation of the patent’s two independent claims in a way that enlarged their scope (In re Ecofactor, Inc., No. 24-2081 (Fed. Cir. Jan. 21, 2026)).

COPYRIGHT LEGISLATION: A bipartisan House bill introduced January 22 would create an administrative subpoena process to help copyright owners determine which of their copyrighted works have been used in the training of generative artificial intelligence models. Titled the “Transparency and Responsibility for Artificial Intelligence Networks (TRAIN) Act,” the measure proposes adding a new section to the Copyright Act to create this mechanism. The bill (H.R. 7209) is sponsored by Representative Madeleine Dean (D-Pa.) and cosponsored by Representative Nathaniel Moran (R-Tex.). A version of the legislation was introduced in the Senate on July 24, 2025 (S. 2455). That bill is sponsored by Senator Peter Welch (D-Vt.) and cosponsored by three of his Senate Judiciary Committee colleagues, Marsha Blackburn (R-Tenn.), Adam Schiff (D-Calif.), and Josh Hawley (R-Mo.). Similar legislation was introduced in the 118th Congress but did not advance.

COPYRIGHT OFFICE NEWS: On January 22, the U.S. Copyright Office released an updated version of its copyright registration and recordations bulk dataset. The Office said it was the first major update since the Office initially released bulk data on over forty years of copyright registrations and other records in 2022. The original bulk dataset contained information on approximately 20 million copyright registration records from January 1, 1978, to July 8, 2021. The updated version contains approximately 22 million copyright registration records from January 1, 1978, to June 27, 2025.

Attorneys: Rollin A. Ransom (Sidley Austin LLP) for Atlantic Recording Corp. Debra Janece Mccomas (Haynes and Boone, LLP) for Apple Inc. Greer N. Shaw (Graves & Shaw LLP) for Smart Mobile Technologies LLC. Reza Mirzaie (Russ August & Kabat) for EcoFactor, Inc. Fahd H. Patel, U.S. Patent and Trademark Office, for John A. Squires.

Companies: Atlantic Recording Corp.; Anna's Archive; Apple Inc.; Smart Mobile Technologies LLC; EcoFactor, Inc.

News: AINews Copyright Patent TechnologyInternet FedCirNews NewYorkNews