Registering a Group of Updates to a Non-Photographic Database (GRDB)

This page provides guidance for registering a group of updates to a database that does not predominantly consist of photographs. For information on how to register a group of updates to a database that consists primarily of photographs, see Compendium (Third) § 1112.7(B).

Eligibility Requirements

To qualify for this registration option, ALL of the following criteria must be met:

  • The work must qualify as a database.
  • The updates or revisions must be original works of authorship.
  • All the updates or revisions to the database must have the same general title.
  • The subject and general content of the updates or revisions must be similar.
  • The organization of the updates or revisions must be similar.
  • All the updates or revisions must be owned by the same copyright claimant.
  • The database must be fixed in a machine-readable copy.
  • The database updates must be created or published within a three-month period in a single calendar year (e.g., October 1–December 31).

What can be registered?

To be registered with the Copyright Office, multiple updates to a database can be registered together on one group application as long as:

  • The updates were published (or created, if unpublished) within a three-month period in the same calendar year, and
  • Each update included in the group registration is a sufficiently creative new or revised compilation.

Registration may extend to (i) the compilation authorship present in the database, or (ii) the compilation and the new copyrightable content within the records (text, photographs, artwork, etc.) that the claimant legally owns. The group registration only extends to database versions published (or created, if unpublished) within the update period that contain sufficient original or creative compilation authorship that was not published or registered previously.

A group registration does not extend to any update or version within the update period that does not contain sufficient new and/or revised compilation authorship (selection, coordination, and/or arrangement). Without compilation, the content of the data records cannot support a database registration. The content within the data records may be included in the database registration only if the content is (i) copyrightable, (ii) part of a copyrightable compilation, and (iii) owned by the same claimant.

If there is no new compilation in the group of updates, group registration is not possible. Instead, database records containing copyrightable content should be registered separately on Standard Applications.

Example: You selected restaurants from around the world to include in your database. You identified common data points to capture, such as star rating, head chef, year opened, most popular dishes, etc. You categorized the restaurants by cuisine, location, average price, and star rating. You update the database at least once a week. Users cannot browse the data in this database. They can access the data only via a query function.
Updates: Sufficient compilation?

On April 1, you updated the database to include an additional 85 restaurants, which you selected from a diverse pool. You added a small number of photographs of each restaurant you visited.

On May 2, you added 12 more restaurants and the following new data fields: address, related restaurants, dining room capacity, and patio (Y/N).

Yes. The April 1 and May 2 updates contain sufficient revisions to the compilation—there is a creative selection of new restaurants and a creative selection and arrangement of new data fields.

On May 6, you updated the contact information for each of the existing restaurants in the database.

No. You updated existing records but did not change the compilation.

On June 22, you changed the following data fields: you removed the dining room capacity field and added a year closed field.

No. These minor changes to the compilation are not sufficiently original or creative to be copyrightable.

On July 6, you updated the database to include 217 more restaurants, which you selected from a diverse pool.

Yes, but it can’t be registered in the same group as the April 1 updates described above.

A group registration only covers updates that were published (or created, if unpublished) within a three-month period. The July 6 update was created more than three months after the April 1 update. The July 6 update could be registered as part of a group registration for updates in July, August, and September, for example.

Application and Fee

An application for a group of updates to a non-photographic database must be submitted using paper Form TX ($500 fee).

Applications submitted electronically through eCO for a group of updates to a non-photographic database will be refused. The filing fee is nonrefundable.

The Copyright Office’s current fee schedule is available here:


In space 1 on Form TX, the applicant is required to identify the title of the work, the three-month period covered by the registration, and other identifying information about the database in the following manner:

Group registration for database titled ______________; [ Published / Unpublished ] updates [and revisions] from mm/dd/yyyy to mm/dd/yyyy; Representative [ publication / creation ] date: mm/dd/yyyy; Updated [frequency (daily, weekly, monthly, etc)].

Example: Global Foodie Database

Group registration for database titled Global Foodie Database; Published updates from 01/01/2021 to 03/31/2021; Representative publication date: 03/31/2021; Updated daily.

Learn about Representative Dates in the Deposit Requirements section below. For additional guidance concerning this section of the application, see Compendium (Third) § 1112.8(A)

Deposit Requirements

The deposited records must be from one version of the database that was created or published on one day within the update period; this is known as the “Representative Date.”

If the database is unpublished, the deposit material from the Representative Date must have been created on the same day. If the database is published, the deposit material must have been published on the same date.

An acceptable deposit consists of two items:

  1. Fifty pages of complete data records or fifty complete data records of new or revised database content from the Representative Date.

    NOTE: A complete record includes all of the data associated with that record; summary views that only show a portion of the data are not acceptable.

    For example, a complete record for a real estate listing includes all of the data about a property and all of the photographs that are part of the listing.

    NOTE: Revised content must be marked to show the copyrightable changes. If the records deposited contain only new content, you must provide a statement in a cover letter or Note to Copyright Office confirming that all of the content within the fifty data records is entirely new.

  2. A descriptive statement with the following required information:
    • The title of the database
    • The name and address of the copyright claimant
    • A subtitle, date of creation, or date of publication (if any) that may be used to distinguish any separate or distinct data files within the database
    • The name and content of each separate data file, including its subject, the origin(s) of the data, and the approximate number of data records that it contains
    • The nature and frequency of the changes in the database and the location within the database or the separate data files where the changes appear

      NOTE: The nature of the changes should describe how the selection, coordination, and/or arrangement of material in the database is sufficiently creative.

    If the database contains a copyright notice, the descriptive statement should also include the following information:

    • If the notice is in a machine-readable format, the applicant should provide the exact content of the notice and indicate the manner and frequency with which it is displayed (e.g., at a computer when a user signs on, continuously on the computer screen display, on printouts from the database, etc.).
    • If the notice appears on copies of the database or on magnetic tape reels or the containers for those reels, the applicant should submit a photocopy or other sample of the notice.

Sample Form TX for a Group of Updates to a Non-Photographic Database

A blank fillable PDF version of Form TX is available here.

For more information about the group registration option, please see U.S. Copyright Office, Compendium of U.S. Copyright Office Practices, Third Edition (2021) §§1112 (general guidance), and 1112.7(A) (deposit requirements).