the introduction in which Schucman discusses the process by which she wrote down the material, i.e. by hearing the Voice, it is clear from the context that the purported source of the material is some divine being. In fact, Defendants repeatedly assert that the Course indicates clearly that its author is Jesus. Given Defendants' burden of proof on this defense, there has been a failure to show that the Copyright Office would not have had notice of the divine authorship of the Course notwithstanding the failure to name Jesus as an author in the application. See Urantia, 114 F.3d at 963 (rejection of fraud on the Copyright Office defense because even though plaintiffs did not reveal divine authorship of Urantia Book, they submitted copies with their application and the "Book clearly describes its own origin").
- 3. Chain of Title
FIP's certificate of registration of the Course constitutes prima facie evidence that it possesses a proper chain of title, in this instance, that the copyright passed from Schucman to FIP by oral assignment prior to registration. Under the 1909 Copyright Act, in contrast to the current statute, an assignment of a copyright "did not have to be in writing to be enforceable." Self-Realization Fellowship Church v. Ananda Church of Self-Realization, 206 F.3d 1322, 1325 (9th Cir. 2000); see also Magnuson
40
