Statutory Termination of Transfers/“Recapturing Copyrights”: Statutory Termination Provisions Are Limited to the United States

An argument may be made that if a grant of worldwide rights is made in the United States under United States law and the grant is subsequently terminated by the author or his/her heirs pursuant to Section 304(c), 304(d), or 203 of the Copyright Act, then the termination would end the grantee’s rights throughout the world. However, the customary understanding is that because the termination right is unique to the United States copyright law, only the grant of rights in the territory of the United States is subject to termination.