Statutory Copyright Damages Based on Number of Works Infringed

According to an October 2, 2004 article by Robert R. Begland, discussing Venegas-Hernandez v. Sonolux Records, "the U.S. Court of Appeals for the First Circuit has made clear that statutory damages under the federal Copyright Act are to be calculated based on the number of works infringed, not the number of different commercial formats in which the infringed work appears. This holding is in accord with many other courts which have considered the issue."