June 9, 2014 Update:
In May 2014, the United States Supreme Court ruled the Copyright Act, 17 U.S.C. § 100 et seq., allows plaintiff to bring an action for copyright infringement 18 years after the initial act of infringement for continuing infringements. Petrella v. Metro-Goldwyn-Mayer (May 19, 2014, 2014 DJDAR 6168). The look back period is controlled by the Act statute of limitations, which is three years. The defendant does not have the equitable defense of laches, which is unreasonable and prejudicial delay of the plaintiff in bringing the action. The Petrella case involved the alleged infringing work of the movie Raging Bull, based on the life of boxing champion Jake LaMotta. The plaintiff, Paula Petrella, is the daughter of the original copyright owner, Frank Petrella, who with Jake LaMotta created the 1963 screenplay.