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Appeals courts have affirmed existence, application of discovery rule vs injury rule under Copyright Act. 3 yr limit for damages does not apply when plaintiff unaware of past infringements, filed suit within 3 yr of discovery.
Under the Copyright Act of 1976, a civil action for copyright infringement must be "commenced within three years after the claim accrued." 17 U.S.C. § 507(b). But when does a claim accrue.