Universal Copyright Convention
In the judgment Kaplan considered Patry's arguments, the Copyright Clause in Article One of the United States Constitution, the Berne Convention for the Protection of Literary and Artistic Works, the Universal Copyright Convention, and the Berne Convention Implementation Act of 1988 (BCIA). In particular, it considered sections 3(a) and 4(a) of the BCIA, which amend title 17, chapter 1, § 101 of the United States Code.