In the case of Parissi v. Telechron, Inc., 1954, the United States Supreme Court ruled that a copyright infringement claim could not be brought in federal court without first having registered the copyrighted work with the U.S. Copyright Office. The plaintiff, Joseph Parissi, had composed a song and sold it to various customers without registering for copyright protection. When he discovered that his song was being used by Telechron Inc., he filed suit alleging copyright infringement but failed to register his work prior to filing suit as required by law at that time. The Supreme Court held that registration is a prerequisite for an infringement action under federal law and dismissed Parissi's lawsuit.

In the dissenting opinion for Parisi v. Telechron, Inc., Justice Robert H. Jackson disagreed with the majority's decision to deny copyright protection to a work that had been published without notice of copyright as required by law at that time. He argued that such an interpretation was too strict and did not align with the intent of Congress when it enacted the Copyright Act. According to Justice Jackson, Congress intended for authors to have broad protections over their works and this should include situations where they inadvertently fail to comply with technical requirements like providing notice of copyright upon publication. The justice also expressed concern about how denying protection in these cases could lead to unfair outcomes where innocent authors lose rights over their works due solely to minor errors or oversights.