good cover letter for at kearney

The Kearney Interview: Our Complete Guide to Acing It

Last Updated June, 2024

Recruiting season for the consulting industry is coming up fast, so it’s time to get familiar with what consulting interviews look like and to practice the skills needed to pass them. In this guide, we’ll cover all aspects of the Kearney Interview so that you can make the most of your opportunity.

Consulting interviews are tough, but My Consulting Offer was founded and is staffed by former recruiters and consultants from top consulting firms. We’ll cover what’s in the AT Kearney interview and give you tips on how to prepare.

In this article we’ll cover:

Kearney’s history and culture.
The Kearney recruiting process.
The Kearney case interview.
The Kearney fit or behavioral interview.
How to prepare for a written case interview.
Our 5 tips on acing the Kearney interview.

Let’s get started!

Kearney History and Culture

The kearney behavioral interview, the kearney interview process, the kearney written case interview, the kearney case interview, our 5 tips on acing the kearney interview.

Kearney was founded in 1939 after Andrew Thomas Kearney, the then Managing Partner at McKinsey’s Chicago office, split with the firm and founded McKinsey, A.T. Kearney & Company. However, McKinsey bought the sole right to use the “McKinsey” name and therefore, in 1947, Tom Kearney renamed the company to A.T. Kearney and Company.

In 2020, the company shortened its name to Kearney, and refreshed its brand to reflect what clients have always praised about its culture: that its consultants work side by side with clients in a real and relatable way, making their business transformation straightforward and enjoyable. This has led to Kearney’s standout success.

Today, Kearney is a global team of 4,200 people in more than 40 countries. Kearney “aims to be the difference of purpose for their clients, people, communities, and the planet by pursuing sustainable positive results in everything they do, as established in the principle of ‘essential rightness.’ ” Kearney fulfills this mission for their clients through their daily work – deploying advanced technological know-how and talent to create lasting economic, social, and environmental solutions.

The 5 Core Values within “Essential Rightness”

“Our success as consultants will depend on the essential rightness of the advice we give and our capacity for convincing those in authority that it is good.” – Kearney Founder Andrew Thomas Kearney

Guided by their principle of “essential rightness,” Kearney prides itself in hiring people who live their 5 core values – curiosity, generosity, boldness, solidarity, and passion – to create a holistic and sustainable positive impact for the clients, people, and community at large. People who “live the essential rightness” have:

Curiosity and drive to explore new ground.
Generosity of spirit to care deeply about the well-being of others.
Boldness to be distinctive and break from the status quo.
Solidarity to be a winning team that supports each other and their well-being.
Passion and presence to be their best self.

Since 2020, Kearney has been hosting Kearney Values Awards to celebrate colleagues firmwide and showcase people’s contributions to these 5 core values.

The culture of Kearney is open, supportive, and non-hierarchical with a strong emphasis on teamwork and collaboration. Teams are encouraged to openly discuss any issues / challenges. In addition, Kearney places core emphasis on mental health and encourages team members to embrace holistic health at the workplace. For instance, Kearney organizes its Global People Care Jam to provide an opportunity for its people to co-create actionable ideas that help build a mentally healthy workplace.

We recommend watching 2 short videos on Kearney’s collaborative culture and CEO Alex Liu’s take on the 5 core values to understand what differentiates Kearney from other consulting firms.

The Kearney interview process follows these steps:

Submit your resume and cover letter on Kearney’s online application system.
First round interviews are conducted in-person or through phone/video call. You can expect two 45-minute interviews. One interview will be focused on a case interview while the other will be focused on behavioral or fit interview questions. Your interviewers will likely be associates or managers.
Second round interviews are led by senior managers, principals, and partners. Typically, you can expect to have three 45-minute interviews. Two of these interviews will be focused on a case interview and one will be focused on behavioral or fit interview questions. But the interview structure depends on the position you’re applying for, so confirm the specifics with your recruiter.
Written case: You will be given a case-study handout and will need to present your case-solving approach and recommendations in PowerPoint slides, followed by a case presentation.
Excel skills test: You will be provided with a pre-made Excel worksheet and will be asked to perform analysis using functions such as Vlookup, Sumif, Countif, Index, Match, etc. You can use LinkedIn Learning or other resources to master these skills.
Receive your decision. After successfully navigating the Kearney interview process, you’ll finally receive the coveted letter that welcomes you as the newest member of Kearney’s team. Congratulations!

Nail the case & fit interview with strategies from former MBB Interviewers that have helped 89.6% of our clients pass the case interview.

The Kearney case interview is a business problem that you solve live with guidance from an interviewer. Our Ultimate Guide to Case Interview Prep explains in-depth what the case interview is and details its various stages:

The opening,
The structure,
The analysis, and
The conclusion.

It also gives you tips on how to become proficient at each stage. The best way to get smarter about answering case interview questions is to master this 4-part approach.

The Kearney Case Interview: The Details

Kearney case interviews are designed to assess your quantitative skills, business logic, and strategic thinking. Kearney case interviews are typically more quantitative and numerical than other consulting firms’ . So, expect to perform math calculations during your case.

Kearney case interviews are candidate-led, similar to BCG and Bain cases. This means you are expected to “drive” the case using the information provided to you. Consider the interviewer your biggest asset and keep drawing on him/her to share more information as you progress through the case.

The best way to approach a Kearney case interview is to enter the interview as a consultant would enter a client’s office or board room – ready to use your imagination, gather and analyze information, arrive at solid conclusions, and communicate persuasively. Remember to:

Clearly scope the problem statement by asking preliminary questions. Spend enough time processing the problem statement and clarifying it with the interviewer to make sure that you are solving the right problem.
Structure your case solving approach by laying out the buckets of issues you plan to solve and organizing them logically. Get feedback from your interviewer as you move from one bucket to the next while solving the case to ensure you’ve fully covered each topic.
Over-communicate. Articulate your initial hypothesis including the data you need to prove/disprove that hypothesis. Communicate key assumptions or limitations of your approach so that your interviewer knows you are aware of them.

For practice, we recommend going through this Kearney case example .

Given the firm’s focus on quantitative cases, expect Kearney case interviews on market sizing. To set you up for success, we’ve created a detailed guide to help you ace Market Sizing Questions . It details 2 approaches you can use to accurately estimate and answer any market sizing question.

Finally, Kearney does the majority of its work across the procurement, sourcing, and operations sectors. Therefore, if you have a background in this area, it’s ideal if you prepare for cases focusing on these topics to “wow” your interviews and land the coveted offer. But if you don’t have that type of background, don’t worry. Kearney will train new hires.

The behavioral and fit elements in the Kearney interview assess whether you have the personal qualities required of a successful consultant and whether you can use them effectively within the Kearney culture. The interview is used to gather information on your past behavior and performance in order to evaluate and predict your future success with Kearney.

Be prepared to answer questions about your experience with teamwork, conflict resolution, and leadership.

Common Kearney Behavioral Interview Questions

Kearney interview questions – Fit assessment:

Tell me about yourself.
Walk me through your resume.
Why Consulting?
Why are you interested in working for Kearney?
What are your strengths and weaknesses?

Kearney interview questions – Personal Experience Interview (PEI)/ Behavioral assessment:

What is the most challenging project you’ve done?
Tell me about a team conflict you managed and your learnings from it.
Tell me about a time when you had to change a stakeholder’s mind.

As you prepare for these questions, it’s relevant to note that the richer you make your story, the better your answers will be. Use these tips from Kearney to guide your preparations for your behavioral/ fit assessments:

When you tell your interviewers about the setting, always explain the interpersonal dynamics present in your situation, and share external influences that impacted your decision.
You should paint the picture for your interviewer and use vivid/colorful language to bring your examples to life.
Make sure that at the conclusion of your example the interviewer knows why that decision was made and feels that he or she could have done the same thing.

Head to our comprehensive article on Consulting Behavioral Questions to learn how to prepare strong answers for the behavioral interview questions.

Kearney is one of the few firms that test candidates via written case interviews. Let’s break it down step-by-step so that you know what to expect and how to prepare to come out with flying colors.

In a written case interview, your written work and analysis become the center of discussion. You’ll be given slides/handouts that contain information in a text-based format. Some will contain charts and data tables pertaining to the case. The objective is to absorb that information, identify opportunities or the root cause of the problems presented, and then synthesize (not summarize!) your recommendations for the clients. In other words, don’t just repeat key points from what you’ve read, but use that data to develop a point of view on how to solve the problem. You’ll then be asked to present your solution to the interviewers in a PowerPoint slide format.

The written case tests your quantitative skills as you work through the data to prepare analysis, and it tests your synthesis and communication skills as you write down your recommendations and present them to the interviewers. Typically, you will have:

~1 hour to complete the analysis and synthesize recommendations
30 minutes to present your work: ~20 minutes to walk through your slides and ~10 minutes for Q&A with your interviewers.

We recommend that you go through our comprehensive guide to cracking Written Case Interviews to set yourself up for success.

1. Brush Up on Case Interview Math

Kearney places strong emphasis on quantitative skills. This doesn’t mean that you need to learn regression and coordinate geometry. But you should be comfortable with simple business analytics (e.g., linear equations with single variables, basic mathematical formulas applied in day-to-day business, such as Profit = Revenue – Costs).

Chances are you’ll be required to perform quite a bit of mathematical analysis during your case interviews. And if you’ve prepared well on math fundamentals, then you’ll feel “in control” of the case analysis and exude confidence. And that’s exactly what you want your interviewer to take away!

To prepare, head to Case Interview Math to learn the different types of math problems tested in cases and equip yourself with the right tips and techniques to minimize math mistakes. Make the numbers work for you!

2. Practice Productive Problem Solving

The Kearney case interview requires you to organize and analyze data. Therefore, you should practice making your problem-solving process as productive as possible:

Where multiple data sources exist, think through the accuracy and relevance of each and be ready to make judgment calls on how to interpret and present them.
Where data does not exist, form an initial hypothesis and be ready to share how you would go about testing it and sourcing the data.
Ensure you cover all the relevant factors in your overarching case structure before you begin to deep-dive into any single issue. You shouldn’t come across as someone who can intuitively think of a few factors but who jumps too quickly into case solving. The ideal candidate will spend sufficient time understanding the problem statement, scoping out different factors contributing to the case, and ensuring that no critical piece of information is left untouched. If you are able to set up a strong structure, then solving the case becomes much more streamlined.
Remember to continually check in with your interviewer as you move forward from analyzing one issue to the next. Share your hypotheses and rationale behind each of your moves. This makes your thinking clear and builds rapport with your interviewer.

We recommend that you review Our Ultimate Guide to Case Interview Prep to master the 4 stages of problem-solving during the case interview.

3. Exude the “Essential Rightness”

Demonstrate that you have the qualities that Keaney looks for in candidates – curiosity, generosity, boldness, solidarity, and passion – throughout your interviews . Kearney consultants pride themselves on having a long-term vision, being analysis-driven, and bringing holistic and sustainable impact to their clients. During your Kearney case interview,

Try not to force your solution to fit a standard framework. Understand the problem statement, the business, and the objectives before laying out any framework for problem-solving.
Do not speak before thinking carefully and holistically. Base your hypotheses on supporting data. Always share your rationale and critical thinking with the interviewer.
Do not search for a silver bullet. Complex problems rarely have simple solutions and your interviewers acknowledge this. There is never a “right” answer (even in a quantitative case). As long as you’re logical in your approach, cover all issues exhaustively, and engage your interviewer in case solving, you’re golden!
A passion for learning,
A collaborative nature,
Good business acumen,
Confidence but not arrogance, and
Poise under pressure.
Lastly, try to avoid using jargon or buzzwords. It’s better to be simple and direct.

4. Build a Story

The simplest way to ace your behavioral interview is to give your interviewers a good reason to remember you. Make your answers memorable by weaving them together into a strong and compelling narrative.

Build stories using your past experiences before your Kearney interview.
Highlight the impact that you brought to the team, to the project, to the organization in your previous roles.
Spend time demonstrating your potential to your interviewer, talk honestly about your strengths and weaknesses, and be yourself. After all, it’s your story! The interviewers are looking for genuine people who have integrity, are helpful and collaborative, and are fun to work with.

5. Confidence Is Key

As a consultant, you’ll work on challenging business problems, face difficult clients, and encounter difficult situations. You’ll need to stay calm and confident. This is also exactly what your interviewer will be testing for. The interviewers are taking cues from your body language as you respond to their questions, as you solve the case, even as you present your recommendations.

One way to naturally feel more confident is to practice in the days or weeks leading up to the interview. The more case practice you have under your belt, the more calm and composed you will stay during the interview. For instance, if you appear nervous or shaky in your quantitative skills, the interviewer may not see you as someone who will build Kearney’s credibility with clients. Therefore, you must exude confidence not only in your voice but also in your body language. The way you walk into the interview room, how you sit up, your eye contact with the interviewer, the way you solve the case – everything matters.

Remember to smile, pause, respond calmly, reflect before you answer, and humbly admit what you don’t know. Confidence is the key to cracking the Kearney interview process.

We wish you the best!

– – – – –

In this article, we’ve covered:

The Kearney Consulting interview process.
An overview of Kearney case interviews (including the Kearney written case) and behavioral / fit assessments.
5 Tips on acing the Kearney interview.

Still have questions?

If you have more questions about the Kearney interview, leave them in the comments below. One of My Consulting Offer’s case coaches will answer them.

Other people prepping for their AT Kearney case study interview found the following pages helpful:

Our Ultimate Guide to Case Interview Prep
The Kearney Recruitment Test
Consulting Behavioral Interviews
Written Case Interviews

Help with Case Study Interview Prep

Thanks for turning to My Consulting Offer for advice on consulting interview prep. My Consulting Offer has helped almost 85% of the people we’ve worked with to get a job in management consulting. We want you to be successful in your consulting interviews too. For example, here is how Brenda was able to get her offer from BCG.

3 Top Strategies to Master the Case Interview in Under a Week

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Kearney Case Interview Guide (process, questions, prep)

Kearney interviews are tough compared to regular interviews at other large companies. The questions are difficult and the interview format is specific to Kearney.

But the good news is that with the right preparation it can actually become relatively straightforward to succeed at a Kearney interview. We've put together this ultimate guide to maximise your chances of success.

Here's an overview of what we'll cover.

About Kearney
Kearney interview process overview
Kearney case interviews
Kearney behavioural questions
Kearney case presentations
How to prepare for Kearney case interviews

Practise case interviews 1-to-1 with Kearney ex-interviewers

1. about kearney ↑.

Today, Kearney is among the world's most prestigious consulting firms. It brought in $1.3bn in revenue in 2022 and has around 4,200 employees globally, across 40 different countries. Kearney also ranked #7 in the top consulting firms to work for in the 2022 Vault Consulting 50 .

The company used to be called "AT Kearney" but dropped the initials as part of a major rebranding in January 2020 .

Right, let's take a look at the Kearney interview process.

2. Kearney interview process overview ↑

Below we outline the typical interview process if you're applying to join Kearney's "general consulting" path as a Business Analyst or Associate.

Kearney also has an Analytics team and a Technology & Engineering team. If you're applying for one of these, this guide will still be relevant for you but be prepared to face some additional technical interviews.

Kearney has three main steps in its application process:

Resume and cover letter screening
Two first-round interviews
Between two and four final-round interviews

These steps outline the typical process. However, the exact process can vary based on location and role. It can be really helpful to ask your HR contact if they can provide more details on your specific interview track.

2.1 Resume and cover letter screening

First, Kearney's recruiters will look at your resume / application and assess if your experience matches the open position. This is the most competitive step in the process—we’ve found that 90% of candidates don’t make it past this stage.

You can use this free resume guide and this free cover letter guide to help tailor your application to the position you’re targeting.

And if you’re looking for expert feedback, you can also get input from our team of ex-MBB recruiters , who will cover what achievements to focus on (or ignore), how to fine tune your bullet points, and more.

2.2 First-round interviews

If your application is approved, you'll face two first-round interviews of ~ 1hour duration.

Typically, each will be a case interview, but with the first 15mins dedicated to behavioural or fit questions. Your interviewers will be managers and associate consultants at Kearney.

If you're applying on-campus at a target school, then you may have your interviews in-person. Otherwise, the first round is usually done over the phone or through a video call.

2.3 Final-round interviews

If you get past the two first-round interviews, you'll face at least two more case interviews in the final round.

These case interviews may start with 15 mins of behavioural questions, as before. However, this time the interviewers will be more senior members of the firm - i.e principals and partners.

If you're an undergraduate, you may be invited to an Assessment Centre for the final round interviews you will likely face a group case presentation also.

If you're an MBA or experienced hire, you'll usually interview at a Kearney office, and in addition you'll have to give a written case presentation.

Both experienced and graduate candidates may also have a behavioural interview with a partner as a final test to make sure you're the right fit for the firm.

In the following few sections, we'll explain how you can prepare for all your interviews and give yourself a great chance of landing a job as a Kearney consultant.

Let's get started!

3. Kearney case interviews ↑

Case interviews at Kearney are candidate-led, which is the same style used in a BCG or Bain case interview . This is different than firms like McKinsey that use interviewer-led cases.

For a candidate-led case interview, there are 7 types of questions you need to prepare for:

Framework development
Framework exploration
Quant question – Data provided
Quant question – No data provided
Creativity question
Recommendation

In addition to the question types mentioned above, you should also expect to see market sizing questions during your AT Kearney interviews.

You can learn more about case interviews and how to prepare in our free case interview guide .

Another great way to prepare is by practicing with realistic sample cases. There are a few free AT Kearney practice cases available online, and you can find them at the links below:

Case example: promotional planning (Kearney website)
Kearney case book (old AT Kearney practice cases)

You can also get a sense of what candidate-led case interviews are like, using the video below. As we mentioned, case interviews at Kearney tend to be candidate-led and therefore use a format similar to BCG and Bain interviews.

4. Kearney behavioural questions ↑

As we outlined above, Kearney tends to ask behavioral questions at the beginning of your case interviews, and these tend to be "fit" questions. However, you may also face a purely behavioral interview, and here you're likely to face a more situational or "PEI" type of question. Let's take a look at both types:

Fit questions. These are generic questions such as “ Why consulting? ” or “ Why Kearney? ”.
Personal Experience Interview (PEI) questions. These are questions such as “Tell me about a time when you led a team through a difficult situation.” Or “Tell me about a time where you had to manage a team conflict”

Here are the top 5 fit and PEI questions you should prepare for at AT Kearney.

5. Kearney case presentations ↑

In addition to case interviews and behavioural interviews, which are both common for consulting firms, Kearney also uses case presentations. If you're an undergraduate, you will probably do this as part of a group, while if you're an MBA or experienced candidate you may have to do an individual, written presentation.

Take a look below at whichever applies to you.

5.1 Kearney written case presentations

The typical format is:

~ 1-hour to review materials and prepare a PPT presentation
~ 10-minute presentation in front of interviewers
Q&A with interviewers at the end

It's worth mentioning that this does vary, so if you're already in contact with a recruiter from Kearney, you may want to ask them for more precise details.

With that said, for this type of interview you'll usually be provided with some materials containing data and background information for the case. You may also be provided with questions that your presentation should specifically address.

During your prep time, you will need to conduct an analysis, collect supporting arguments, and prepare a PowerPoint to deliver your findings. You should also prepare to be challenged by your interviewers with follow-up questions.

You can learn more about preparing for this type of interview in our written case interview guide . That guide is written with BCG and Bain in mind, and there are some differences for an Kearney case presentation. However, the tips and preparation plan in sections 2 and 3 would still be a great resource for your preparation.

5.2 Kearney group case presentations

As mentioned in section 2, group case interviews are sometimes used in the Kearney interview process, usually for undergraduates during their Assessment Centre day. Here is the key information you need to be aware of for this type of interview:

Candidates get divided into groups of 4 to 6
Each group is given information about a case (i.e. a client facing a problem)
You are given 10-15mins to review the materials by yourself or with another person in your group
You are then asked to discuss a few questions about the case for 20mins with the rest of your group in front of your interviewers
The interviewers will ask a few questions to the group for 15 to 20mins

This type of case mainly tests your ability to work with others. Interviewers won't intervene during the group discussion. They will just observe the group dynamics and mark each participant based on how they are contributing to the discussion.

Here are the top 3 things you should aim to do in your group interview:

Speak with a purpose. At the beginning of a group discussion, a lot of candidates will want to speak their mind as they know participating is important. But participating is not enough. The QUALITY of your input is crucial. Sometimes, it's better to let two or three people get the discussion started. And to then make a very thoughtful point based on how they started the discussion. Focus on the quality of your input, not the quantity.
Involve everyone. Another tip that's easy to apply is to keep an eye on who's participating in the conversation and who's not. If you identify a member of the group who's struggling to make themselves heard, you should not hesitate to help them be heard by saying something like: "We haven't heard everyone's opinion on this yet. John, Rebecca what do you think?"
Summarise. Finally, at the end of the 20 minutes group discussion it's a good idea to summarise the different points people have made. This will position you as the person bringing everyone together and making sure all candidates are on the same page. It is something some partners in consulting like doing with clients in real life and will therefore reflect positively on you.

And the top 3 things you should really avoid doing :

Looking very nervous. Group interviews is the time to put your poker face on. Everyone is stressed in a group interview. But you need to try your best to come across as confident. A good way to do this is to focus on basic body language: look at people in the eye, sit confidently, don't cross your arms, try not to fiddle with your hands, etc.
Interrupting others. Consultants need to be client-friendly, and interrupting someone in a discussion is not client-friendly at all. You should listen carefully to what others are saying. Try to have a genuine interest in what they think. Before making your point, summarise their point to show that you understand what they mean.
Dominating the conversation. Finally, some candidates are so eager to participate in the conversation that they end up completely dominating the rest of the group without realising it. A good tip to avoid this is to keep an eye on how much time you talk. If you are in a 5-person group you should aim to speak 20% (1/5th) of the time and really no more than 25%.

Your performance in regular and group case interviews will play a big role in the firm's decision to give you an offer. If you'd like to learn more how to approach group interviews, check-out our separate detailed guide to group case interviews.

6. How to prepare for your Kearney case interviews ↑

6.1 learn the case interview essentials.

The best starting point for your case interview prep is our case interview prep guide . It'll take you through all the different types of questions you may be asked in your case interview, show you how to draw from different frameworks to structure your answer, and give you example cases to practise with.

6.2 Become really confident at maths

You don't have to have a perfect GPA or GMAT score to succeed at case interview maths. However, during your Kearney interviews, you will be expected to quickly perform accurate mental maths.

In order to do this, it’s essential to know the formulas for common metrics, like return on investment or breakeven point. And it’s also helpful to know a few maths shortcuts to help you solve problems more quickly. To learn more about these topics, check out our free guide to case interview maths .

In our experience, the most successful applicants start their interview preparation by practising maths skills, so make sure you prioritise this step.

6.3 Research the company

Kearney interviewers want to hire candidates who are deeply motivated to work for their firm. Read up on Kearney's values and culture , and present yourself accordingly.

Also, you'll want to make sure you're up to date in the latest developments in the area of the company you're applying to join. The Kearney insights page is a good

In addition, try to do some networking ahead of your interviews so that you can show you've made the effort to reach out to current staff.

6.4 Do mock interviews

How you solve each case is important, but your interviewers will also be evaluating how you COMMUNICATE your answers. It's important to speak in a structured way that makes it easy to clearly understand your points.

The best way to hone your communication skills is to practise interviewing out loud, and you can do that in three main ways:

Interview yourself (out loud)
Practise interviewing with friends or family
Practise interviewing with ex-interviewers

To help you with this process, here is a broad list of consulting interview questions you can practise with. Practising by yourself is a great way to get started, and can help you get more comfortable with the flow of a case interview. However, this type of practice won’t prepare you for realistic interview conditions.

After getting some practice on your own, you should find someone who can do a mock interview with you, like a friend or family member.

We’d also recommend that you practise 1-1 with ex-interviewers from Kearney . This is the best way to replicate the conditions of a real case interview, and to get feedback from someone who understands the process extremely well. Meet our MBB ex-interviewers who’d love to work with you.

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A.T. Kearney Cover Letter Example

Cover letter best practices and template for 2024 - a.t. kearney.

A.T. Kearney is a renowned global management consulting firm, well known for its strategic and operational CEO-agenda issues facing businesses, governments and institutions around the globe. The firm offers a wide range of opportunities for career growth in different domains such as strategic consulting, business technology, and operations consulting. A.T. Kearney is deeply committed to fostering an inclusive culture, centred on diversity, meritocracy, and mentorship. The diverse and global structure of the company offers unique perspectives and enriching collaboration opportunities, making it a favourable environment for professionals wanting to excel in management consulting. Writing a compelling cover letter is crucial for catching the attention of hiring managers. Statistics show that a well-crafted cover letter increases your chances of getting an interview by over 50% . Your cover letter should be tailored to the specific job you're applying for, highlighting your relevant experiences and demonstrating your enthusiasm for the role. It's not just about reiterating your resume; it's about providing a narrative that shows why you're the right fit for the job . Use your cover letter to tell your story, focusing on how your skills and experiences align with the job description and company values . Employers appreciate cover letters that are concise, clear, and direct, typically preferring documents that are no longer than one page. By following these guidelines, your cover letter can make a strong impression, setting the stage for your resume and propelling you towards the interview phase.

Our A.T. Kearney Cover Letter Template

Cameron Martinez

[email protected]

(715) 613-7271

Dear A.T. Kearney Hiring Team, I am a strategic thinker Business Management Consultant with 2 years of experience and I'd love to join your team, as seen on your Career page. In my current position I have led a team that successfully improved operational efficiency over the last year and now I'm excited to continue my journey by contributing and growing at A.T. Kearney. Here’s why I believe I'd be a perfect fit for the position: First, I’ve always been intellectually curious about comprehending how thing work in the Management Consulting sector. As a Business Management Consultant at Deloitte, I wanted to push myself and understand each specific of my day to day. Before starting my career, I've obtained a Bachelor's Degree in Business at Harvard University. These academic skills were the foundations which helped me to become the go-to person to ask about identifying issues and formulating hypotheses. Second, I have plenty of experience conducting research to understand the business landscape and current operations. At Deloitte, I’ve managed delicate situations related to develop strategic recommendations based on findings and presenting to senior leadership and been successful at meeting approaching deadlines where I had to think quickly on my feet. As the company scaled, I’ve taken increased responsabilities including mentoring and helping newcomers adapt to company culture. Finally, I am excited about A.T. Kearney's vision and core values. As a team player and adaptable Business Management Consultant, I recognize the importance of working in a company with a collaborative and dynamic atmosphere. I am genuinely excited about the opportunity to contribute to A.T. Kearney, and I am ready to commit to the high standards and ambitions your team upholds. Thank you for considering my application. Sincerely, Cameron Martinez

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Career in Consulting

All about the Kearney Recruitment Process

If you want to get a job at Kearney, you might ask yourself how the Kearney recruitment process works.

In this in-depth guide you’ll learn:

How to write a resume and cover letter that pass the Kearney screening phase
How to pass the Kearney recruitment test
How to stand out during Kearney fit interviews
How to ace the Kearney case interviews
And lots more

So, if you want to go through the rigorous and challenging Kearney hiring process successfully, this guide is for you.

Let’s get started!

An overview of the kearney recruitment process.

From the time you apply until you accept the job offer, you will have to progress through a series of steps in the Kearney recruitment process.

Most of the time, this process takes between two and three months, with often 14 days between steps on average.

Check this article to learn more about the exact preparation and interview timelines you should expect when interviewing at Kearney.

Show Your Uniqueness: The Resume And Cover Letter Screening

Your resume , with a cover letter , is the first step to a very lucrative job at Kearney.

Yet, less than 30% of applicants receive a call for an interview.

So, what is Kearney looking for when screening your resume and cover letter?

First, Kearney Is Looking For Academic Performance

A recent study from poetsandquants.com shows which schools are the top MBA feeders in the consulting industry.

For instance, top MBA programs with good placement in the consulting industry include MIT, London Business School, INSEAD, and Columbia Business School.

Secondly, Kearney Is Looking For Specific Qualities

Like any other top consulting firm, Kearney assesses if you possess the required skills to be a Kearney best-in-class consultant.

Those skills include your capacity to break down problems logically, prioritize the most important components of a problem, analyze data, connect different sources of information to derive conclusions, etc.

And if you want to develop those skills to ace your case interviews, I’ve created a full (and free) course here .

In this free course, you’ll find plenty of examples to turn your Kearney interviews into a lucrative job offer.

You can sign up for free for this case interview course .

Furthermore, Kearney is looking for people with certain characteristics .

Because if you possess these characteristics, Kearney knows that you’ll fit their culture and potentially become a top consultant.

Therefore, all your resume and cover letter content should demonstrate that you have mastered these skills and characteristics .

To be more precise, your resume and cover letter content must show how you used these skills and the IMPACT you had .

Lastly, Kearney Wants To Understand Your Motivation To Join Them

Kearney wants to understand your motivation to join Kearney: Are you genuinely interested in joining Kearney over McKinsey, BCG, or Bain?

Thus, your cover letter must show that you have researched the firm, talked to its consultants, and have persuasive and tailored arguments for why Kearney is your first choice.

Are your cover letter and resume ready for applications?

Check these 2 articles to learn how to write winning resumes and cover letters and get many examples: consulting resume, a step-by-step guide (2023) , and writing a persuasive and customized cover letter .

Don't Stress Out: The HR Screening Interview

In most cases, the HR screening interview is conducted by phone and is aimed at briefly reviewing your background.

For instance, the HR screening interview can include a list of questions such as :

Background questions : for example, “Tell me about yourself” or “Describe your work history.”

Motivational questions : “Why are you interested in consulting?” and “Why Kearney”?

Specific skill-based questions : for example, “Tell me about a time when you had to solve a problem in a team”

For this stage, you can expect a 20-minute interview.

Note : more on how to answer those questions later in this guide.

Show Your Logical Reasoning: The Kearney Recruitment Test

As a Business Analyst at Kearney, you will spend much time reading and analyzing data (from a graphical chart or an Excel spreadsheet).

Besides, you will have to derive insights from these data and connect these insights to your client’s problem.

The Kearney Recruitment Test assesses your ability to complete these tasks well.

In other words, the Kearney Recruitment Test (or Kearney Screening Test) assesses your ability to do the job: if you do well on the test, it indicates that you will perform well as an Analyst.

Indeed, this test has been designed to assess how you use deductive, inductive, and quantitative reasoning abilities to solve problems logically.

You’ll have to answer 40 multiple-choice GMAT-like questions in 60 minutes.

The multiple choice test is divided into three parts that assess your quantitative and verbal reasoning.

You are not allowed to use a calculator during the test.

In addition to facing challenging questions, candidates are typically under a lot of time pressure

Get 4 Complete Case Interview Courses For Free

You need 4 skills to be successful in all case interviews: Case Structuring, Case Leadership, Case Analytics, and Communication. Join this free training and learn how to ace ANY case questions.

Do NOT Neglect It: The Personal Experience Interview (PEI)

After the screening process, there is a selection process consisting of multiple interviews.

First and foremost, I want to point out a mistake made by too many candidates:

Do NOT neglect your preparation for this part of the interview.

Indeed, the PEI counts for 50% of your assessment. In other words, candidates often fail to secure an offer after falling flat on the PEI – even with perfect case-cracking skills.

What To Expect During The PEI

During each of your Personal Experience Interviews, you can expect the four following types of questions :

First, “ Tell me about yourself ” or “Walk me through your resume.”

Then, “ Why Consulting? “.

Thirdly, “ Why Kearney? “.

Finally, between one and five behavioral interview questions .

You can expect the PEI (or fit interview) to last between 20 and 40 minutes.

Now, let’s go through these 4 types of questions.

Tell Me About Yourself

As I write in Tell Me About Yourself: How to Answer This Question , you never get a second chance to make a first impression.

This question, or common variants such as “Walk me through your resume,” is an easy and open-ended start to a conversation where your interviewer wants to know the following:

What are your motivations, and what drives you?
Which problems you had to solve, and how you solved them ?
What is your academic background?
How do you deal with people ?
What impact have you had in the past?

Why Consulting?

A natural question following “Tell me about yourself” is “ Why consulting? ” .

Because the second most important thing that Kearney wants to know after who you are is:

if you understand what Consulting is,
and if you are truly interested in pursuing a career in that industry .

Why’s that?

Because Kearney doesn’t want you to leave after six months after you realize that the consulting lifestyle doesn’t fit your objectives.

So, whether Consulting is a thoughtful career choice or an “I don’t know what to do, let’s try” career choice, there are many good reasons why Consulting can be a good opportunity.

7 Reasons Why Consulting Can Be A Good Career Opportunity

#1 - It's a good career choice after University if you don't know what to do : if you don't know what to do after University or after your MBA (you're not alone!), then Consulting is a safe bet. You'll have the opportunity to explore which career, sector or specialty is right for you
#2 - You'll have a strong impact : you'll have the opportunity to work on and solve the most pressing problems faced by big corporations
#3 - You'll have a strong exposure to C-level Executives : early on in your career, you'll work directly for CEOs, CFOs, CMOs, etc. and start developing the soft skills to become a senior Executive later
#4 - You'll learn a lot : Consulting firms invest a lot in training their consultants. In addition, the feedback culture is very strong and you'll get full performance reviews regularly
#5 - You'll work with bright people : consultancies pride themselves on hiring bright and interesting people. Plus, with 3-month projects on average, you'll meet a lot of different people in consulting
#6 - You'll have the opportunity to work in an international environment : large consultancies sell work to businesses and governments all around the world
#7 - You'll have access to an amazing alumni network : having worked in a consulting firm will give you access to its alumni network that will help you throughout your career

2 Other Reasons Why Consulting Can Be A Good Career Opportunity (But You Can't Tell Them To Your Interviewer)

#8 - You'll have great exit opportunities : headhunting firms or big corporations love ex-consultants. Even now, 5 years after I left Consulting, head hunters still contact me on Linkedin to point out interesting opportunities
#9 - You'll earn a lot of money : consulting is also known as a very well-paid industry. The average base salary for a McKinsey Associate is $127,000 a year according to Glassdoor. Plus, your salary will increase between 10% and 25% each year

Besides listing a couple of reasons why you want to pursue a career in consulting, a compelling answer should explain WHY these reasons are important for you .

Check this article to learn how to craft a compelling answer to the “Why consulting?” question.

Why Kearney?

Next, “Why Kearney?” : This question evaluates your motivation to join Kearney.

I have explained in this article how to have a compelling answer to this question.

Behavioral Interview Questions

Next, your interviewer will ask you between 1 and 5 behavioral interview questions .

For instance:

Describe a challenging situation when you have had to work hard to achieve something, in a limited time, outside your comfort zone
Tell me about a time when you have had to work with someone with an opposing opinion
Share an example where you effectively worked with people with different backgrounds
Revisit a time when you experienced significant change or encountered an ambiguous situation and share the actions you took to adapt to the new circumstances
Discuss a hypothetical client scenario to help us understand how you structure tough, ambiguous challenges, identify important issues, deal with the implications of facts and data, formulate conclusions and recommendations, and articulate your thoughts

The McKinsey PEI to understand in-depth how to ace your fit interviews
The STAR framework revisited to craft amazing stories based on your experiences

Be Exceptionally Structured: The Case Interview

The case interview is another problem-solving test.

Kearney believes the best way to assess your problem-solving skills is to discuss a real client scenario with you .

This helps them understand how you structure tough, ambiguous business challenges, identify important issues, deal with all the implications of facts and data, formulate conclusions and recommendations, and articulate your thoughts in a fast-moving discussion

For instance, watch the following video with a candidate solving a market sizing question :

Interviewer Led vs. Candidate Led

The Kearney case interview follows the candidate-led case study interview format .

What does that mean?

First, your interviewer will present a problem.

Then, you must ask clarifying questions to define clearly the problem.

Next, you must structure an approach to solve this problem.

And you, the candidate, take the reins, guiding the interviewer through your approach.

It’s your stage, and interviewers are more spectators.

Finally, your interviewer will ask you a set of pre-determined questions, regardless of what your initial structure is.

For instance, here are the types of questions you can have:

Problem structuring – organize the problem into an issue tree
Trend analysis – review a graph and synthesize information relevant to the client
Quantitative analysis – solve a simple mathematical calculation without a calculator and synthesize the results for the client
Synthesis – the partner or client CEO is in the elevator with you. What do you recommend they do?

See each of these questions like a “mini” case:

You will have to understand the problem, develop a mini structure, ask for additional data (if necessary), and come to a conclusion that answers the question.

Good examples of interviewer-led cases can be found in the sample cases on the Kearney website .

Furthermore, you can read my free case interview guide .

Kearney Wants You To Succeed

Unlike in many industries, management consulting firms tell you exactly how to interview; the challenge is meeting Kearney’s level of excellence.

To help you and other candidates succeed, Kearney shares these resources:

AT Kearney interview prep tips
AT Kearney case interview examples: here and here

I want you to succeed, too. The internet holds hundreds of example cases. I recently shared a list of 250+ practice cases .

Related article : 11 must-know frameworks to ace your case interviews.

You’re Almost Done: Ask the Interviewer Great Questions

You’ve made it through the behavioral and case study portions.

Now, the interviewer asks if you have any questions .

Kearney is genuinely interested in your questions . Interviewers want to know you are passionate about consulting and working at Kearney.

Here are some ideas for great questions:

Make a connection with your interviewer . Ask questions about their background and their current work that interest you
Explore the culture of the office at which you are interviewing
Clarify the structure of the office, Kearney, or client engagements

You can read this article to build your list of smart questions to ask at the end of your interviews.

The Infamous Blacklist: Does It Exist? And How to Overcome It

The jury is out on if there is a Kearney blacklist.

Here’s what I do know: only apply if you are ready to interview .

Management consulting is a destination job for university programs and experienced hires.

Competition is strong .

For instance, if you do not pass the interviews, consulting firms will request you wait 12-18 months until you reapply .

Even then, Kearney may want to see a significant career change as evidence your skills have improved to pass another set of interviews, such as through a graduate degree, significant promotion, or work at a top-tier company.

Don’t dwell on the question of the blacklist, but remember, competition is tough. Be confident before you interview.

Offered an interview but not feeling ready? I can help you prepare in as little as 4 weeks .

The Kearney Recruitment Process: Conclusion

To conclude, you now better understand the essentials of the Kearney interview process.

Curious about the recruitment process for other top firms? Read more here:

McKinsey & Company
Bain & Company
Boston Consulting Group

Now I want to hear from you:

Do you have any questions about the process?

With which part of the process do you struggle the most?

Kearney Case Interview Guide 2024: Format, Criteria, Example

Kearney is one of the world's leading management consulting firms, with a presence in over 40 countries and almost 100 years of founding. The firm is renowned for its excellence in strategy, operations, and organization and works with three-quarters of the Fortune Global 500.

To land a job at Kearney, you must pass the Kearney case interview, a practical screening tool to measure potential candidates' abilities to be a consultant. This article will look closely into this assessment and discuss what to expect and how to ace the Kearney case interview.

Table of Contents

What is Kearney case interview?

Kearney case interview is the last test to become a kearney consultant.

The Kearney case interview is the screening interview of Kearney , where candidates must solve business problems (or cases). The interview evaluates whether candidates possess the capabilities and qualities to become an Kearney consultant.

Kearney case interviews are candidate-led , requiring you to lead and manage every step of the case-solving process, including structuring the issue, developing frameworks, requesting data, synthesizing findings, and providing solutions. The interviewer just presents the topic, instead of asking questions concerning the case.

Before getting to the case interview, you must pass the initial screening rounds, which include resume screening and an online test.

In the resume round, you’ll of course need a consulting resume, just like what you’d need for McKinsey, and a cover letter, then submit it on Kearney’s website.

The online test concerns numerical, verbal, and logical reasoning questions. It’s quite similar to McKinsey’s problem solving test before it was retired and replaced by the problem solving game.

There are two rounds in the case interview process

Kearney interviews are actually quite straightforward with two rounds:

Round one with one 45-minute case interview and a behavioral interview

Round two with two 45-minute case interviews and a behavioral interview

Experienced and MBA candidates will face a written case

The written case is used by Kearney to simulate the actual work of a consultant, in which they need to visually plot out data and insights. It’s quite similar to the oral case, only you’re writing out your thought process instead of speaking it out.

After receiving the case, you’ll have one hour to review materials and prepare a PowerPoint presentation, then 10 minutes to pitch it to interviewers . After that there will be a Q&A. We’ll touch on this later.

Kearney looks for those with achieving & analytical mindset

Just like all management consulting firms, Kearney looks for those who want to make an impact. The main value Kearney will look for are:

Outstanding academic achievement: Your GPA and school prestige. Your best bet? 4.0 at Harvard! But jokes aside, a 3.6 GPA should be good. Below that? Try to make focus points in other parts of your resume. This article might help!

Analytical ability: The ability to create a thorough, data-driven, insightful analysis and define the root cause and solutions to difficult problems. You show this in the case interview via constructing issue trees, answer guesstimate questions, etc.

Demonstrated leadership : The ability to inspire and motivate others. Consultants won’t simply look for “leaders” who just tell their subordinates what to do, but a guiding beacon, even for their superiors (very much like telling your boss what to do, but, think of it as inspiring ideas to them).

Collaborative approach : The ability to exchange facts and insights and effectively interact with people from various backgrounds and cultures. You’ll meet people hailing from mathematics, engineering, accounting, psychology, so play your collab cards right

Intellectual curiosity : The ability to actively and continuously seek and expand knowledge

How to prepare for Kearney case interview

Careful preparation is a must to ace Kearney’s case. You can tackle each aspect of the interview step by step.

Start from getting used to candidate-led cases and written cases, then further out with business intuition, consulting math, fundamentals & frameworks of case interview, then finally conduct mock interviews.

Step 1: Get used to the candidate-led case interview, and written case interview

Examine examples of candidate-led case interviews to familiarize yourself with the case flow and how to interact with the interviewer.

You can also get familiar with more case interview samples and all instantly-effective tricks for case interviews with our Case Interview E2E Secret Program. Also, here’s our free video of a case interview example with an explanation and expert comments.

Step 2: Develop business intuition

Having business intuition significantly improves your performance in case interviews. Working on intuition is a gradual process that takes practice every day. You can improve your business intuition in two ways:

Written sources: Read business papers daily (Bloomberg is recommended). You can also find articles on McKinsey, Bain, and BCG’s websites. But be careful! The important thing is not your page count, but what you absorbed from them

First-hand experience and observations: Don't just do things like a machine; find out what the seniors are doing, why they did what they did, and how it has affected the organization. Everything is a learning process, and it’s up to you to squeeze out every bit of knowledge and experience

Step 3: Practice consulting math

Consultants work with quantitative data in just about every minute. It simply takes too long to whip out a calculator every time they need to calculate something, and you’re definitely not impressing clients with that. That’s why interviewers place such high emphasis on mental math skills. To improve your math, you can:

Train your head : Apply mental calculations on any daily occasion unless an EXACT answer is required

Start small : Use a piece of scratch paper, give yourself some margins of error (5% is a good start); once you get used to it, remove the paper and narrow down the margin of error.

Establish a routine : Spare time for daily practice and get better each day, just like exercise. You’ll never notice the little changes, but they stack up HARD, and when you realize it, you’re probably doing math thrice as fast

Step 4: Learn the fundamentals and frameworks of case interview

Kearney case interviews (or any other case interview) are based on the fundamentals - using hypotheses and issue trees, the MECE principle, and the frameworks. So, knowing them is extremely important and you should practice the fundamentals until you are comfortable.

A common mistake candidates make during their case interviews is to go straight for the frameworks. Frameworks require extensive adaptation to match actual cases. To customize appropriately, you must understand the fundamental knowledge first.

To know more about case interviews, here’s a dedicated article .

Step 5: Conduct mock case interview

Mock interviews are a great way to simulate the actual case interview session. You should examine your cases in great depth during the mock case interview. Record your session, replay, note the comments, and look for ways to improve.

Find a former consultant to help you with your practice - they are the ideal people; they've been there, they’ll know what a candidate must be.

Through their feedback, you can improve on what needs to be improved and boost your chance of getting an offer.

We can also help you connect with consulting coaches (all former consultants!) for a more personalized feedback. Book your mock case interview session with us now !

And don’t forget the fit questions

Fit interviews are intertwined with case interviews in the Kearney interview process. They set the tone for the interview, and the interviewer’s impression of you, so make sure to try your best, even if they don’t really weigh as much as the case. Nobody likes a bad impression, eh?

Notes on written case interview

If you’re an experienced or MBA candidate, you also need to prepare specifically for Kearney’s written case interview. Here are some tips:

Enhance fast reading skills

Improving your reading speed will help you process data faster, allowing you to single out the important pieces. You can learn the tips to improve your reading speed in this speed reading techniques article.

Craft your data-analysis skills

The ability to analyze data is the core of the hypothesis-driven approach in consulting. You analyze the information to determine the root cause, formulate a hypothesis, and support your suggestion. To enhance your data analyzing skills for your written case interview, practice data interpretation skills (reading charts, tables, graphs…).

You can also find out more on this with our Numerical Reasoning Package .

Learn to make consulting slides

In the written case interview, your job is to organize the layout of graphs, tables, findings, and recommendations in a “consulting” style (on paper or in PowerPoint).

In real consulting work, the PowerPoint engineers (yes I call them that because they’re so good) will add the bells and whistles to create the final slides for your pitch.

We have a whole article on how to craft and present MBB/consulting slides . Check it out to learn the step-by-step guide.

Deliver a timed and solution-driven pitch

The first thing you should do is to allow a specific time limit for each step of the pitch. When that time limit reaches, stop what you're doing (like skimming data) and move on to the next (like structuring the problem). Also, spare some time for contingency for any errors occurring.

Second, your presentations and pitches should begin with the conclusions and chart titles with the most important insights.

Clients won’t care about the procedures; they want results . So, present the solution , back up with the evidence from your analysis, and recap the pitch.

Scoring in the McKinsey PSG/Digital Assessment

The scoring mechanism in the McKinsey Digital Assessment

Case Interview End-to-End Secrets Program

Elevate your case interview skills with a well-rounded preparation package

Case interview is the final stage of L.E.K hiring process with 3 phases: CV screening, online tests and interviews. The last stage consist of 2 different rounds

Case interview is the last round of ZS Associates hiring process with 3 stages: online application, aptitude tests + video interview & 2 parts of case interview

PwC case interview is the last round of the hiring process. To get to this round, you must pass the previous 3 rounds: resume, online test & video interview

This question is about A.T. Kearney .

How do you write a cover letter for a job at A T Kearney?

You write a cover letter for a job at AT Kearney by focusing on your skills and experiences that best align with the job at hand and a company that is a trusted advisor to the world's foremost financial organizations.

With the freedom to be yourself and recognition for what you bring, we're individual and inclusive to our core. While our values unite us, our desire to be a difference for our colleagues, our clients, and society at large sets us apart. If you're ready to make the shift from performing to thriving, let's chat.

AT Kearney is looking for talented individuals who not only can get the job done but who also can represent the company's mission and values.

They want talented professionals who can help drive high-impact strategic transformations by taking full advantage of exponential technology change and getting to the core of multiple issues and opportunities quickly and efficiently.

Its mission is to help you drive high-impact strategic transformations by taking full advantage of exponential technology change and getting to the core of multiple issues and opportunities quickly and efficiently.

A T Kearney's Core Values:

We will create a trusting space to share perspectives, surface complex topics, and identify our biases in an open and forgiving environment

We will celebrate inclusive leadership to ensure individuals bring their best selves to each collaboration in honor of the global society in which we operate.

We will lift up those that need support, providing practical help, education, and unity, in conjunction with our network of experts and allies.

We will respond and change in a timely manner, championing social justice, racial equality, and inclusion always.

How do you write a cover letter for a job at A T Kearney?

Search for jobs

A.T. Kearney Jobs

Learn more about a.t. kearney jobs.

What benefits does AT Kearney offer?

How do you answer "why are you interested in working for A T Kearney?"

Does A T Kearney hire felons?

What is the dress code at A T Kearney?

How old do you have to be to work at A T Kearney?

Zippia Answers
How Do You Write A Cover Letter For A Job At A T Kearney

Does anyone has an AT Kearney Cover letter and Resume sample and is willing to share it? Thanks in advance

Overview of answers.

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I interviwed with A.T.K, and I don't think you should be using a template, because the recuiters read thousands of CLs, and you want yours to stand out. Just be sure to address 'why ATK?' and 'why you?' Be sure to display a throrough understanding of the firm and their approach to problem solving, thier culture and brand within the industry. If you can swap ATK for McK or BCG in your cover letter, and all statements still hold true, you probably need to customize it a bit more. You could talk about exciting initiatives they have underway, some of their recent work that you admire, etc. You should probably talk to someone in the firm to get more insights.

Here are some links to get started:

https://www.youtube.com/watch?v=qH7p0GuQER4

https://www.atkearney.com/why-were-different

http://www.vault.com/company-profiles/management-strategy/at-kearney/company-overview

All the best!

Thanks a lot great insights. Can you have a look at my CL if possible?

Hi Arham, which office are your applying for ? Best Benjamin

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Sample cover letter for Internship position at at kearney

Business analyst.

My name ---- is and I will graduate next April from a Master of Science at ---- I am strongly motivated to pursue a career in management consulting and my recent internship at ---- has reinforced my will. Therefore, I am writing you to express my interest for an internship position in the ---- offices.

I am attracted by A.T. Kearney’s culture, collaborative with its clients and within the firm. It means to me that A.T. Kearney offers a high level of client exposure and thus great opportunities for a rapid professional growth. I believe that the supportive environment promoted within the firm is very useful for fostering personal and professional development and for putting any employee in the best conditions to maximize his or her inputs in a project. Given the high caliber of A.T. Kearney’s clients, I am sure that at A.T. Kearney I could find continuous opportunities to challenge myself and to have an impact. Further, the ambitious objective of being the most admired management consulting firm by 2020 proves how much A.T. Kearney is focused on growth and people development and this highly motivates me to join your firm.

I am an energetic and ethical individual and I believe that my skills would make me an asset to A.T. Kearney. I am very flexible and adaptable; moving abroad twice as a student has helped me in developing such skills and made me comfortable in dealing with unusual situations. The intern position at ---- sharpened further my problem solving and analytical skills. My prime responsibilities were to perform data analysis tasks for benchmarking and discrepancy analysis purposes. I have been effective in discerning the needed information and in performing accurate analyses. Furthermore, this experience honed my interpersonal skills by being part of a team and by being often involved in meetings with the client’s management. In addition, a constant attention to the overall project flow made be able to develop good project management skills.

I like to be challenged and I believe that A.T. Kearney could fulfill my aspiration. I look forward to hear from you to reaffirm my enthusiasm and to know more about A.T. Kearney. In the meantime, I thank you for your time and consideration.

Sincerely,

Rising Star

Kearney 🐠, what do you like about your firm? I’m writing a cover letter for the Dubai office but I’m struggling not to make it generic! Any advice / tips would be greatly appreciated!

We got the softest blanket ever in the americas.

Pretty dope blanket as our only WFH perk in 2020! Screw them stipends, who needs 💵

Helpful and talented colleagues across offices, global presence, good coverage of offerings within both functions and industries, strong challenger spirit. Good luck with the application!

Lol wow really unhelpful guys 😂. op - just dm me and i’ll help out.

Thanks K1! 💯

OP - happy to talk of that helps My suggestions 1. Write why you really are applying (don't try to pander to us), even if you said I just want to try it for 2-4 years, that's fine by us 2. Talk to folks if you can, know us 3. As some of my colleagues said, cover letter is useless if you are just writing it for the sake of it, a well written story always resonates 4. In reality we want to know you, why you want to work with us rather than some historical artifact that we already know Hope this helps Cheers

Thanks Bharat, I really appreciate those points!

Smaller size, entrepreneurial mindset. Best idea wins regardless of level.

You’re better off going through a recruiter.

Thanks, that’s super helpful! I’ll reach out to them!

Is the cover letter required? If not skip it, hardly anyone reads them anyway

It is apparently, applications without a cover letter may not be considered,

Feel like everytime I have a potential job the moment I interview face to face it all falls apart. Are there certain key mistakes you guys notice that detract from someone even if they have good work?

Hey Milbank lawyers, curious how many hours is 80% utilization for you?

Is 55k good salary for one person working and living in Vienna Austria? Tech : Oracle DBA , Yoe : 7 yrs

Hi everyone can i claim car rental on my maternal uncle rc but he is having same name and same sir name as me . Will they approve it??

I selected a Lenovo laptop but was sent a Dell. What's the chances I'll be able to request a replacement with a Lenovo after onboarding? I want a Lenovo because I'm love my TrackPoint nub!

What is the hierarchy structure at PwC India Consulting

what should be the ideal CTC for person having 9 Years experience? Bank of America Tata Consultancy Accenture Deloitte USI

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Setting start of year objectives vs post year end reviews

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Group Registration of Updates to a News Website

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Supplementary information:, i. background, ii. final rule, a. eligibility requirements, 1. works that may be included in the group, i. constitutional challenge, ii. news website limitation, iii. website limitation, 2. scope of collective work, 3. one-month limitation, 4. authorship, ownership, and work made for hire requirements, 5. subjects of inquiry, i. permitted additional title information, ii. permitted archived urls, b. filing fee, c. deposit requirements, 1. “home page” requirement, i. timing of deposit capture, ii. “complete copy”, 2. site maps, 3. additional deposit suggestions, 4. other comments, e. application requirements, f. conclusion, list of subjects, 37 cfr part 201, 37 cfr part 202, final regulations, part 201—general provisions, part 202—preregistration and registration of claims to copyright, enhanced content - submit public comment.

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U.S. Copyright Office, Library of Congress.

Final rule.

The U.S. Copyright Office is creating a new group registration for frequently updated news websites. This option will enable online news publishers to register a group of updates to a news website as a collective work with a deposit composed of identifying material representing sufficient portions of the work, rather than the complete contents of the website. The final rule is nearly identical to the provisions set forth in the January 2024 notice of proposed rulemaking, with one modification in response to public comments and one to reflect a technical change in the process for submitting these claims.

Effective July 22, 2024.

Rhea Efthimiadis, Assistant to the General Counsel, by email at [email protected] or by telephone at 202-707-8350.

The Copyright Act authorizes the Register of Copyrights to specify by regulation the administrative classes of works for the purpose of registration and the deposit required for each class. [ 1 ] In addition, Congress gave the Register the discretion to allow registration of groups of related works with one application and one filing fee. [ 2 ] This procedure is known as “group registration.” [ 3 ] Pursuant to this authority, the Register has issued several regulations permitting group registrations for certain types of works, including newspapers, newsletters and serials, unpublished works, unpublished and published photographs, contributions to periodicals, secure test items, works on an album of music, short online literary works, and database updates. [ 4 ]

This rulemaking expands the available group registration options because of several factors specifically impacting news websites. Along with receiving requests from online publishers, the Office observed the increase in news content offered online and the dynamic nature of such material. [ 5 ] It also reviewed stakeholder comments in prior proceedings that discussed the challenges associated with registering online news content, including those submitted in response to its 2022 Copyright Protections for Press Publishers report. [ 6 ] Finally, the Office acknowledged the deposit challenges associated with websites, particularly news websites, in its 2011 publication titled Priorities and Special Projects of the United States Copyright Office (October 2011-October 2013) . [ 7 ]

On January 3, 2024, the Office published a Notice of Proposed Rulemaking (“NPRM”) to establish a new group registration option for frequently updated news websites. [ 8 ] The proposed rule would allow an applicant to register a news website as a collective work (including any individual component works it fully owns, such as literary works, photographs, and/or graphics) [ 9 ] with a deposit composed of identifying material, rather than the complete contents of the website. The proposed rule would also allow registration of the news website and any updates published within one calendar month, if the deposit evidences a sufficiently creative selection, coordination, or arrangement within each collective work to constitute a copyrightable compilation. [ 10 ] Each Start Printed Page 58992 collective work must have been created as a work made for hire, with the same person or entity named as both the author and copyright claimant. The proposed rule stated that applicants would be required to submit their claims through the online copyright registration system, using the application currently in use for a group of newspaper issues. [ 11 ]

The Office received twenty comments in response to the NPRM. [ 12 ] All but one [ 13 ] supported the Office's proposal to create the new group registration option, though the majority requested various modifications. Two commenters, however, expressly conditioned their support on substantive changes to the rule, which would substantially change its scope. [ 14 ] In general, commenters were interested in expanding eligibility for this option to a greater number of works and changing the deposit requirement. Proposals included revising the definition of “news website,” removing the work made for hire and author/claimant requirements, increasing the time limitation for updates to the news website, clarifying the “home page” deposit requirement, and asking the Office to confirm the scope of remedies for copyright infringement of a collective work. [ 15 ] Finally, one commenter encouraged the Office to “identify opportunities for improvement” and to remain “adaptive to technological changes.” [ 16 ]

Having reviewed and carefully considered each of the comments, the Office now issues a final rule that is nearly identical to the proposed rule, with one modification reflecting concerns raised by some commenters regarding the “home page” deposit requirement and one modification concerning the application form for this option. These modifications are discussed in more detail below. With respect to requests that we received to expand the scope of the rule, the Office will closely monitor how the new group option performs, including the number and complexity of the claims submitted, the amount of time needed to examine these claims, and the modest filing fee for this option. The Office remains open to revisiting these issues in the future based on this rule's performance.

In the NPRM, the Office proposed to limit this group registration option to updates to a “news website,” defined as “a website that is designed to be a primary source of written information on current events, either local, national, or international in scope, that contains a broad range of news on all subjects and activities and is not limited to any specific subject matter.” As described in the NPRM, the proposed rule stems from the rapid development and predominance of news websites over print newspapers, [ 17 ] and requests from news publishers for a feasible way to register “newspaper websites” that are “updated frequently.” [ 18 ] Thus, the proposed rule is an extension of the existing group newspaper option that has been available for decades. [ 19 ] Consistent with the Compendium of U.S. Copyright Office Practices, the proposed rule defines a “website” as “a web page or set of interconnected web pages that are accessed using a uniform resource locator (“URL”) organized under a particular domain name.” A number of commenters encouraged the Office to expand the type of works eligible under the rule and recommended revisions to both definitions.

Before turning to the requests to expand the rule, the Office addresses the argument made by a small number of commenters that the proposed group registration option would violate the First Amendment by limiting the option to a particular type of work. In a joint comment, NWU, NPPA, and NASW stated that restricting the option to “news” websites constitutes “[c]ontent-based discrimination,” which they considered “[c]onstitutionally suspect and subject to strict scrutiny” that the rule “cannot meet.” [ 20 ] In support of this argument, they cited Arkansas Writers Project v. Ragland, 481 U.S. 221 (1987), which reviewed a state sales tax scheme that taxed general interest magazines, but exempted newspapers and religious, professional trade, and sports journals. Because Arkansas “advanced no compelling justification for selective, content-based taxation of certain magazines,” the Supreme Court held the tax scheme invalid under the First Amendment. [ 21 ] Analogizing the tax scheme in Arkansas Writers Project to the proposed registration option, NWU, NPPA, and NASW argued that the exclusion of any web content that does not meet the “news website” definition is unconstitutional. [ 22 ]

Aligned with NWU, NPPA, and NASW, another commenter, Gordon Firemark, contended that, by limiting the group option to updates to news websites, the proposed rule “excludes other types of content from [its] benefits” and denies content creators “relief from the burdens of the current system.” [ 23 ] He argued that recent Supreme Court precedent concerning trademark registration requires a content-neutral approach. [ 24 ]

The Office disagrees with these arguments. It is correct that the Supreme Court has held that content-based laws—laws restricting or compelling Start Printed Page 58993 speech based on its communicative content—are presumptively unconstitutional, [ 25 ] and subject to strict scrutiny, under which the government must show that the law is the “least restrictive means” of advancing a “compelling” governmental interest. [ 26 ] A regulation can be content-based “on its face,” if its text applies to speech based on the subject matter, topic, or viewpoint of that speech. It can also be content-based if it has a discriminatory purpose that “cannot be justified without reference to the content of the regulated speech” or was “adopted by the government because of disagreement with the message” conveyed. [ 27 ] However, a regulation that places “a differential burden on speakers is insufficient by itself to raise First Amendment concerns.” [ 28 ] The tax scheme in Arkansas Writers Project was found to violate these principles by being directed at particular subjects, thus targeting a small group within the press. [ 29 ] That is not the case here.

The Office's proposed group registration option is not analogous to the unconstitutional tax statute in Arkansas Writers Project for multiple reasons. First, the option does not restrict or compel speech based on its communicative content. Nor does it favor or disfavor particular topics or subjects, or exclude a small group of the press. [ 30 ] Instead the option is available for updates to news websites that contain a broad range of topics regardless of the content of the speech involved.

Second, the registration option is viewpoint neutral and operates not as a restriction on speech, but as a condition for qualifying for one of many options available to register copyrights, including online websites and other publications. The Standard Application is available to any type of author for any type of work within the statutory categories. [ 31 ] Group registration options are discretionary accommodations offered by the Office in a number of areas. Currently, the Office administers ten group options covering unpublished works, short online literary works, works on an album of music, serials, newspapers, newsletters, contributions to periodicals, published and unpublished photographs, automated databases, and secure test items. [ 32 ] For online publications, group serials and group newsletters are other registration options for publications that fall outside of the “newspaper” or “news website” definitions.

The Supreme Court's recent ruling in a case involving trademark regulations supports the Office's view. There the Court reviewed a rule of the U.S. Patent and Trademark Office (“USPTO”) barring the registration of trademarks that use the names of particular living individuals without their written consent. [ 33 ] The Court held that this bar, though content-based, is viewpoint neutral and does not violate the First Amendment. [ 34 ] The Court noted that while its precedents “distinguish between content-based and content-neutral regulations of speech,” [ 35 ] they further distinguish “a particularly `egregious form of content discrimination'—viewpoint discrimination,” which targets not merely a subject matter, “but particular views taken by speakers on a subject.” [ 36 ] The Court identified “[s]everal features of trademark [law]” that “counsel against a per se rule of applying heightened scrutiny to viewpoint-neutral, but content-based trademark regulations.” Most notably, it found that “trademark rights have always coexisted with the First Amendment, despite the fact that trademark protection necessarily requires content-based distinctions.” [ 37 ] Accordingly, the Court held that USPTO's “content-based, but viewpoint-neutral, trademark restriction [ ] is compatible with the First Amendment.” [ 38 ]

Similarly, copyright registration, and the broad administrative classification authority Congress granted to the Register, necessarily requires content-based distinctions. Indeed, since its passage in 1976, the Copyright Act has authorized the Register “to specify by regulation the administrative classes into which works are to be placed for purposes of deposit and registration” and to permit “ for particular classes, the deposit of identifying material instead of copies or phonorecords, the deposit of only one copy or phonorecord where two would normally be required, or a single registration for a group of related works.” [ 39 ] Like the USPTO's name bar, these administrative distinctions are not based on the particular views taken by authors and have always coexisted with the First Amendment. The addition of an administrative classification for this new group registration option, which adopts near-identical criteria for determining “news” content to that of the existing group option for newspapers, is “a matter of policy and discretion” [ 40 ] fully compatible with the First Amendment.

Further, unlike the viewpoint-based trademark provisions held unconstitutional for barring registration of scandalous or disparaging marks, [ 41 ] the Office's viewpoint-neutral administrative classification does not bar registration for non-news content or websites. Quite the opposite: to increase participation in the registration system, the Office has created several group options for the registration of works that are published online. [ 42 ] The Standard Application also remains available to any type of author for any type of work within the statutory categories. This rule does not prevent anyone's ability to register non-news works.

Multiple commenters urged the Office to expand the rule's definition of “news website” by removing the condition that the website must contain news on all subjects and activities. [ 43 ] In encouraging Start Printed Page 58994 the Office “not to exclude . . . specialized websites,” the ABA-IPL noted that the “proposed rule may provide especially meaningful benefit to smaller news websites—including those that focus on certain `specific subject matter.' ” [ 44 ] HBP argued that “websites, like HBR.org, that focus on a particular area of news . . . still face the same registration problems afflicting all news websites.” [ 45 ] The Authors Guild also expressed concern that the rule would exclude more specialized news publications, such as those that focus on political news. It argued that “these publications clearly qualify as news websites under any ordinary understanding of that term.” [ 46 ] Relatedly, commenters claimed that content restrictions “put[ ] examiners in an untenable position of deciding what is or is not `news.' ” [ 47 ] Finally, four commenters asked the Office to abandon the “news website” definition and extend the group option “to any periodically-produced content distributed through the internet.” [ 48 ]

After considering this request and in the interest of implementing this final rule as quickly as possible, the Office declines to revise the definition at this time. As an extension of the newspaper group option, the “news website” definition is modeled on the Office's longstanding regulation defining a “newspaper” as a publication that is “mainly designed to be a primary source of written information on current events, either local, national, or international in scope,” that “contains a broad range of news on all subjects and activities and is not limited to any specific subject matter.” [ 49 ] This definition is very broad and it is intended to “make any newspaper eligible for a group registration.” [ 50 ] It is also intended to distinguish a “newspaper” from a “newsletter,” which is defined elsewhere in the regulations as a publication that contains “news or information that is chiefly of interest to a special group, such as trade and professional associations, colleges, schools, or churches.” [ 51 ]

Under this definition, newspapers are aimed at any member of the general public who may be interested in newsworthy information or events that are reported on a given day. [ 52 ] By applying a similar definition to websites, the final rule recognizes that “news websites” are also intended to have universal appeal.

This definition would encompass news websites that cover current events and provide information on diverse topics, including some political websites like those identified in the Authors Guild's comment. [ 53 ] Although these sites focus primarily on issues involving politics and events with political implications, they do not limit their coverage to a particular subject matter nor are they directed at narrow or discrete groups of readers. [ 54 ]

The Office also disagrees with commenters that the “news website” eligibility requirement places a burden on examiners. Indeed, the definitions for “news website” and “newspaper” are similar, in part, to enable consistent application of both rules. Examiners are accustomed to assessing eligibility based on this definition.

However, if the definition proves too rigid or unworkable, the Office is willing to revisit this issue based on its experience in administering this rule. Importantly, however, this new group option is not intended to extend to the websites of all serials or newsletters, which in print or ePrint form have the benefit of separate group registration options. [ 55 ]

The Office received requests to expand the rule beyond websites. Commenters recommended that the proposed rule be amended to include mobile applications (“apps”) in the definition of “website.” [ 56 ] They argued that “[m]any news publishers encourage users to access content on an app rather than a website.” [ 57 ]

The Office declines to amend the definition. It considers an app to be “a computer program that is used directly or indirectly in a computer or handheld electronic device.” [ 58 ] The Office has a procedure for registering the underlying code that operates the app. [ 59 ] To the extent that news publishers seek to register the works published on the app, a registration for a newspaper or a news website would protect those works if they contain the same content.

AIPLA encouraged the Office to revise the definition of “website” to clarify that a website is not limited to content accessed using a single domain name. [ 60 ] It explained that “web pages are composed of various elements, like text, images, and videos” that “might be hosted on a different server than the one hosting the main web page for reasons such as efficiency, speed, and cost.” [ 61 ] The Office appreciates this distinction but declines to revise the definition. To qualify for this option, each collective work in the group must be published under one particular domain name. For registration purposes, the Office does not assess eligibility based on where component digital works may be stored. The Office believes the “particular web page” requirement is necessary to prevent applicants from using the option to register collective works published under different domain names on the same application, which would make it difficult to identify the website that is covered by the registration. Therefore, the final rule retains the definition proposed in the NPRM.

The proposed rule provides that claims registered under this option will be limited to the collective work authorship based on the selection, coordination, and/or arrangement of the individual component works, and that all parts of the collective work will constitute one work for purposes of 17 U.S.C. 504(c)(1) . [ 62 ] Additionally, the Start Printed Page 58995 Office made clear that the registration will also cover the individual contributions contained within the collective work if they are fully owned by the copyright claimant and were first published in that work.

NPR asked the Office to confirm that “the scope of the collective work will explicitly include all copyrightable contributions made by the claimant, not just textual works.” [ 63 ] As noted above, a “news website” is defined as “a website that is designed to be a primary source of written information.” [ 64 ] If the collective work contains individual contributions that are fully owned by the copyright claimant and were first published in the work, then the registration will cover those contributions, so long as they are copyrightable subject matter. However, a component work “that is perceptible to the user only by downloading or separately purchasing that particular work is not considered part of the website for registration purposes and must be registered separately.” [ 65 ] Additionally, any “externally linked content [ i.e., content residing on another website] is not considered part of the website's content for registration purposes.” [ 66 ]

HBP recommended that the Office permit applicants to disclaim content that is licensed and not owned by the applicant. As with group newspapers, the Office does not see the need for a limitation of claim for news websites, because the proposed rule expressly states that “[e]ach update to the website must be [an original] collective work.” A registration issued by the Office pursuant to this rule will only cover the new contributions owned by the copyright claimant. Consistent with any collective work registration, any articles, photos, or other contributions included in the collective work that were previously published, previously registered, owned by another party, or in the public domain are automatically excluded from the claim. As a practical matter, therefore, a disclaimer to expressly exclude material in the application is unnecessary.

Port. Prerogative Club asked the Office to “[c]larify whether updates to numerical information, such as prices, volumes, retweets, or other metrics, qualify as registrable under the rule, and whether the Office has changed its policy on the registrability of short phrases and headlines.” The Office states that its longstanding regulation denying protection for words and short phrases has not changed. [ 67 ] Regarding “prices, volumes, retweets, or other metrics,” it is unclear whether the commenter is referring to individual works of authorship, or whether these items appear in a compilation. Individual numbers and short phrases are not copyrightable. However, a copyrightable compilation of these items may be registrable.

The proposed rule permits an applicant to include updates published on the same website within the same calendar month. Three commenters urged the Office to remove the limitation, arguing that it is too “onerous.” [ 68 ] NPR recommended that the Office allow for the option to cover “three months, or six months, or a calendar year” to “reduce registration costs.” [ 69 ] Noting that “attorneys' fees and statutory damages can be awarded as long as copyright is registered within three months of first publication,” NWU, NPPA, and NASW requested that the rule be amended to allow registration of updates published “during any specified three-month period.” [ 70 ]

At this time, given administrative capabilities, the Office cannot expand the option to cover more than one month of updates. As the NPRM explained, to deliver the option promptly, and to minimize development time, the Office is adapting the existing group application for newspapers, which is used to register up to one month of newspaper issues and contains technical validations that prevent applicants from entering publication dates that are more than one month apart. Changing the limit would require additional modifications to the application and delay implementation of the final rule. Further, the Office seeks an appropriate balance between the interests of copyright owners and the administrative burden to the Office. Based on the modest fee set for this option, some limit on the number of works included in each claim is necessary. The Office will reassess whether the limit can be increased after it has gained sufficient experience administering the rule.

Under the proposed rule, to be eligible for the option, each collective work in the group must have been created as a work made for hire, with the same person or entity named as the author and copyright claimant. Multiple commenters questioned this requirement. [ 71 ] The Authors Guild argued that the work made for hire requirement “arbitrarily and unfairly confines the benefit of the rule to corporate entities even where other creators are producing substantially the same type of content.” [ 72 ] While they recognized that this requirement reflects practical and technical limitations, NMA and AIPLA noted that “there does not seem to be a fundamental reason for such a limitation in principle, and in many business cases, the work may be fully owned by the publisher, or obtained via assignment or operation of law.” [ 73 ]

The Office acknowledges that the work made for hire requirement may not reflect every business case of ownership. However, this requirement streamlines the registration procedures, which, as noted above, will adapt the existing group application option for newspapers. Under that option, the same person or entity must be named as the author and copyright claimant, and each issue must be a work made for hire. The Office retains the same requirements for the news websites option to minimize the need for additional development time that would otherwise be required. Start Printed Page 58996

Additionally, under general Copyright Office practice, if the author and claimant are not the same person, the applicant is statutorily required to provide a transfer statement explaining how the claimant acquired all of the rights initially belonging to the author. [ 74 ] If an applicant names a third party as the copyright claimant, but fails to provide a transfer statement, then the Office must correspond to determine whether the claimant actually owns all of the exclusive rights in the works, which delays the registration decision. The corresponding additional time and costs that the Office would incur are inconsistent with the reduced fee for examination of multiple collective works.

Moreover, imposing a work made for hire limitation is consistent with the goal of this rulemaking, which is to address obstacles to registering online news content produced by news publishers, who often also publish newspapers. Based on its experience with the existing group newspaper registrations, the Office expects that this requirement will produce an optimal public record, while reducing the administrative burden that these claims impose. The final rule accordingly retains the work made for hire requirement. Applicants who do not qualify for the option may still register their works individually using the Standard Application.

The Office invited public comments on whether it should give applicants the opportunity to provide additional information, such as individual article or photograph titles, as part of this group registration option. Commenters expressed support for the implementation of an opportunity to include granular information concerning individual component works at the applicant's discretion. [ 75 ] The Authors Guild noted that “in the event an individual article is the subject of a later infringement action, the applicant may need to rely on its own recordkeeping to establish that the article was on the website during the period covered by the registration.” [ 76 ] It concluded, “[t]he listing of individual titles or other information on the application may provide additional evidence relevant to that showing.” [ 77 ] The Office agrees and will provide instructions on its website explaining how applicants may submit additional information regarding component works on an optional basis. [ 78 ]

The Office also invited public comments on the availability and effectiveness of technological solutions for saving or archiving websites that could assist or supplement news websites' recordkeeping efforts while also informing the public of the contents of the website and/or any updates registered. The Office suggested that applicants may provide in the “Note to Office” field additional information regarding the contents of the work, such as archived URLs that capture the complete content of each collective work submitted for registration. The Copyright Alliance expressed support for this suggestion, provided that doing so is voluntary. [ 79 ] Therefore the Office encourages applicants to submit archived URLs in the “Note to Office” field on a voluntary basis.

The NPRM provided that the filing fee for this option will be $95, the same fee that currently applies to a claim in a group of newspapers. It noted that the Office believes it is reasonable to charge the same fee as for the group newspaper option, given the similarities in expected workflow associated with examining these claims. The NMA expressed support for this modest fee, describing it as “reasonable and unarbitrary.” [ 80 ] The final rule establishes this fee.

The NPRM proposed that for each collective work submitted under this group registration option, applicants must “submit a deposit that is sufficient to identify some of the updates that were made to the website.” [ 81 ] The Office specified that “applicants will need to submit separate PDF files that each contain a complete copy of the home page for the site. Each PDF must show how the home page appeared at a specific point during each day of the calendar month when new updates were published on the site.” [ 82 ] Additionally, the NPRM required that each deposit demonstrate “that the home page contains a sufficient degree of selection, coordination, and/or arrangement to be registered as a collective work.” [ 83 ] Several commenters requested that the Office consider different deposit requirements, though commenters varied on the specific changes they requested or discussed deposits generally. The Office addresses each suggested change below.

After considering NMA's request to resolve a purported ambiguity in the proposed rule regarding the time of day for daily deposits of home pages, the Office is clarifying the time period for capturing deposits. [ 84 ] The language within section (m)(6)(i) requiring “[e]ach PDF [to] show how the home page appeared at a specific point during each day of the calendar month” does not require applicants to capture PDFs of home pages at the same exact time every day. [ 85 ] Instead, PDFs of home pages must show how the home page appeared at some point during each day, in addition to satisfying other applicable deposit requirements.

Three commenters specifically requested that the Office expand the identifying material it will accept to encompass more than “a complete copy of the home page for the site.” [ 86 ] The NAB stated that “the Office should amend the deposit requirements proposed in § 202.4(m)(6)(i) to allow for the submission of a copy of identifying material in lieu of a complete copy of the home page.” [ 87 ] It explained that “many news websites utilize an `infinite scroll' feature that automatically and continuously loads more content as users scroll down the web page” making Start Printed Page 58997 it “technologically impossible for an applicant to satisfy the deposit requirement of providing a PDF of the home page in its entirety.” [ 88 ] Copyright Alliance echoed this sentiment stating “a user is able to continuously reveal additional content on the web page without having to leave the page to view the content on a separate web page. For such web pages, it is not possible to capture an `entire copy' of the page since the user can endlessly reveal the contents of the page.” [ 89 ] Similarly, NMA noted that, due to the difficulties posed by “extensive or close-to-infinite scroll,” the Office should clarify that an applicant could meet the deposit requirement “as long as [the PDF] captures the masthead, URL identifier, and a defined minimum amount of the homepage (which in most cases will encompass all of it), including representative updates from the previous deposit copy.” [ 90 ]

After considering these comments, the Office concludes that the requested modification to the proposed rule is reasonable and supports the overall goal of this group registration option. Accordingly, the final rule includes an alternative to the “complete copy of the home page” requirement where submitting a complete copy is not feasible due to the size or continuous nature of the home page. In such circumstances, applicants may “submit the first 25 pages of the home page that demonstrates updates from the previous deposit copy.” This portion of the rule is designed to decrease the burden on applicants that wish to utilize this group registration option, but are unable to satisfy the “complete copy” deposit requirement. The Office believes that this modification will facilitate registration, while also ensuring that the deposit provided is sufficient to identify the work and the copyrightable authorship covered by the registration. Applicants utilizing this provision are advised that any deposit should only include updates within the time period covered by the application. In the event that an applicant includes updates outside the time period, they would be considered previously published material, and would not be covered by the registration. Additionally, as stated in the NPRM, if a copyright owner is required to prove to a court or an alleged infringer “the specific contents of a website at any particular point in time, it will need to preserve and maintain its own copy of the site and rely on its own recordkeeping to provide such proof.” [ 91 ]

NWU, NPPA, and NASW disagreed that a home page would constitute sufficient identifying material for registration. [ 92 ] They asserted that “requiring deposit of PDFs of images of the home page is disconnected from the reality that updates aren't necessarily visible on the `home page' of a website.” [ 93 ] While “[u]pdates appear on the home pages of some—but far from all—newspaper publishers' websites,” the home pages of other websites, such as self-published or references websites, are “mostly or entirely static,” with updates occurring on other “inside” pages that are not indexed or referenced on the home page. [ 94 ] Instead, NWU, NPPA, and NASW suggested that the Office accept a “sitemap page or set of sitemap pages,” “as the way to indicate which pages of a site have most recently been added or modified, and when.” [ 95 ] Sitemaps, they alleged, “are structured, standardized, machine-readable, and human-readable” and “all updates in a given period can be identified by a single sitemap or set of sitemaps,” which the Office could “use[ ] immediately.” [ 96 ]

The Office declines to permit applicants to submit a sitemap page or a set of sitemap pages as identifying material for several reasons. First, it is not clear that sitemaps themselves provide information that would allow an examiner to determine whether each collective work within the group application contains sufficient creative selection, coordination, or arrangement. [ 97 ] Second, sitemaps do not satisfy the public notice function that deposits serve, as they do not display the work requested for registration and are not sufficient to identify the updates made to the websites. [ 98 ] As explained in the NPRM, any deposit requirement must “satisfy the public notice function of capturing, and making available for public inspection, a deposit that should be sufficient to identify” the work covered by the application. [ 99 ] Lastly, accepting sitemap deposits would likely not aid in efficiency as suggested. [ 100 ] If an examiner receives a sitemap, they would likely need to correspond with the applicant to determine what exactly the application covers. For these reasons, the Office declines to modify the final rule to include sitemaps.

Commenters also suggested that the Office accept deposits comprised of annotated Portable Document Formats (“PDFs”) [ 101 ] or PDF deposits of apps. [ 102 ] Specifically, one commenter encouraged the Office to consider accepting annotated PDFs of a single web page, where “[a]nnotations could circle content that is not included in registration, such as licensed content as compared to original news organization content” or “content already registered.” [ 103 ] Other commenters, including Copyright Alliance, NMA, and the Authors Guild, proposed that the Office should accept PDFs that “contain a complete copy of the home page of . . . mobile application[s]. ” [ 104 ] Start Printed Page 58998 They discussed the ease with which applicants could submit app PDFs [ 105 ] and how PDFs address record-keeping concerns and “concerns over whether the collective works stem from the same source.” [ 106 ] Copyright Alliance and NMA also suggested that the absence of a uniform resource locator (“URL”) from app PDFs, a requirement of the proposed rule, is immaterial because apps “generally prominently feature the logo or other visible identifier of the publication in question” and news content on an app is “organized and contained,” similar to a website. [ 107 ] NMA further recommended that because the USPTO has “long accepted” app screenshots for trademark specimens, subject to certain requirements, the Office should adopt similar standards. [ 108 ]

The Office declines to permit parties to submit annotated PDFs of a single web page. As discussed above, each update will be registered as a collective work. For that reason, there is no need to identify component works that are not owned by the claimant or component works that have been previously registered, because as a general rule, a registration for a collective work does not cover this type of preexisting material.

The Office also declines to accept PDF deposits of apps to represent a news website. Initially, it is unclear whether the selection, coordination, and/or arrangement of material encompassed within the PDFs would be identical to the selection, coordination, and/or arrangement of a website's home page, regardless of whether the same content is present on both. [ 109 ] Further, the Office continues to believe that the rule's deposit regulations offer flexibility, while still satisfying the public notice function of deposits. The regulation will permit applicants to submit a complete copy of the website's home page, and when that is not feasible due to the size or continuous nature of the home page, applicants may submit the first 25 pages of the home page demonstrating updates from the previous deposit copy.

Commenters made additional suggestions and remarks on the proposed rule's deposit requirements and the Office's deposit requirements generally. With respect to the Office's modernization efforts, ABA-IPL suggested that the Office consider generally expanding the “format of deposit copies accepted” and regularly reviewing and updating registration regulations. [ 110 ] ABA-IPL stated that the Office should accept deposits in .xml format for regularly updated news content, such as content covered under the proposed rule, “as [.xml] and similar formats are widely used in digital content creation and management.” [ 111 ] The University of Michigan Library (“UM-Library”) expressed concerns with the proposed regulations regarding fixation and preservation. [ 112 ] They asserted that the proposed deposit requirements are not “sufficiently fixed for copyright purposes” and that if deposit “materials are not collected and preserved—even as facsimiles or through emulation—then as a practical matter there will be a huge gap in the possibilities for research, scholarship, and understanding.”

The Office is sympathetic to commenters' desires to expand the file formats accepted for deposit purposes generally, including regularly updated news content. As stated above and in the NPRM, the current registration system only accepts certain file types. [ 113 ] The Office anticipates revisiting its acceptable file formats in connection with ongoing improvements to its technology systems. Until then, the Office continues to actively engage in research about the suitability of other file formats. [ 114 ]

The Office appreciates the fixation and preservation concerns about the proposed deposit requirements, codified in the final rule. It continues to believe, however, that the deposit requirements are sufficient. As stated above and in the NPRM, the Copyright Act imbues the Register with broad authority to accept identifying material in lieu of complete copies or phonorecords [ 115 ] where such copies or phonorecords are “bulky, unwieldly, easily broken, or otherwise impractical to [serve] . . . as records identifying the work[s] registered.” [ 116 ] This provision, and its legislative history, give the Register flexibility in determining the deposit requirements when identifying material is involved, and the Office has used this authority in the past. Within this rulemaking, the Office believes the proposed deposit requirements are appropriate, and less burdensome than general deposit requirements for websites. [ 117 ] As the Office discussed in the NPRM, the proposed deposit requirements satisfy the public notice function and still require that deposits sufficiently “identify some of the updates” made to the website. [ 118 ] Any fixation concerns may be alleviated by the fact that the proposed regulations are merely registration deposit requirements. They do not relieve a registrant from complying with other legal obligations, such as the obligation to maintain and preserve copies of a website, including its content, in the context of an infringement claim. [ 119 ]

The NPRM explained that the Office planned to use one of its existing group registration application forms to process these claims. Specifically, it said applicants would be required to submit their claims through the current electronic registration system using the application designated for a group of newspaper issues. None of the commenters objected to this proposal.

After consulting with the Library of Congress's Office of the Chief Information Officer, the Office determined that it would be feasible to create a separate application for news website claims that will be cloned from the corresponding application that is used for group newspaper claims. This should simplify the registration process for both applicants and Office staff by preventing potential confusion between claims involving newspaper issues and claims involving updates to a news website. The cloned application will include the same technical specifications and system validations that appear in the group newspaper Start Printed Page 58999 form. The final rule has been modified to reflect this change. Information and instructions on how to submit these claims will be provided in the application itself and on a dedicated page on the Office's website.

Based on requests from affected parties for the expeditious implementation of the rule [ 120 ] and the absence of arguments supporting a delay, the Office finds that good cause exists to issue these regulations as a final rule with an immediate effective date. Commenters have presented a record supporting “the demonstrable urgency of the conditions [the rule is] designed to correct.” [ 121 ] Finally, the registration option authorized by the final rule will be available to registrants at or near the rule's publication date.

General provisions
Copyright claims, preregistration and registration

For the reasons set forth in the preamble, the Copyright Office amends 37 CFR parts 201 and 202 as follows:

1. The authority citation for part 201 continues to read as follows:

Authority: 17 U.S.C. 702 .

Section 201.10 also issued under 17 U.S.C. 304 .

2. In § 201.3, amend table 1 to paragraph (c) by redesignating paragraphs (c)(12) through (c)(29) as (c)(13) through (c)(30), respectively, and adding a new paragraph (c)(12) to read as follows:

Table 1 to Paragraph ( c )

Registration, recordation, and related servicesFees ($) * * * * * * *(12) Registration of a group of updates to a news website95 * * * * * * *

3. The authority citation for part 202 continues to read as follows:

Authority: 17 U.S.C. 408(f) , 702 .

4. Amend § 202.4 by adding paragraph (m) and revising paragraph (r) to read as follows:

(m) Group registration of updates to a news website. Pursuant to the authority granted by 17 U.S.C. 408(c)(1) , the Register of Copyrights has determined that a group of updates to a news website may be registered with one application, the required deposit, and the filing fee required by § 201.3 of this chapter, with each update being registered as a collective work, if the following conditions are met:

(1) Definitions. For the purposes of this paragraph (m):

(i) News website means a website that is designed to be a primary source of written information on current events, either local, national, or international in scope, that contains a broad range of news on all subjects and activities and is not limited to any specific subject matter.

(ii) Website means a web page or set of interconnected web pages that are accessed using a uniform resource locator (“URL”) organized under a particular domain name.

(2) Requirements for collective works. Each update to the website must be a collective work, and the claim must be limited to the collective work.

(3) Author and claimant. Each collective work in the group must be a work made for hire, and the author and claimant for each collective work must be the same person or organization.

(4) Updates must be from one news website; time period covered. Each collective work in the group must be published on the same news website under the same URL, and they must be published within the same calendar month. The applicant must identify the earliest and latest date that the collective works were published.

(5) Application. The applicant must complete and submit the online application designated for a group of updates to a news website. The application may be submitted by any of the parties listed in § 202.3(c)(1).

(6) Deposit. (i) For each collective work within the group, the applicant must submit identifying material from the news website. For these purposes “ identifying material ” shall mean separate Portable Document Format (PDF) files that each contain a complete copy of the home page of the website. In case a complete copy is technically unfeasible due to the size or continuous nature of the home page, the applicant may submit the first 25 pages of the home page that demonstrates updates from the previous deposit copy. Each PDF must show how the home page appeared at a specific point during each day of the calendar month when new updates were published on the website.

(ii) The identifying material must demonstrate that the home page contains sufficient selection, coordination, and arrangement authorship to be registered as a collective work If the home page does not demonstrate sufficient compilation authorship, the deposit should include as many additional pages as necessary to demonstrate that the updates to the news website can be registered as a collective work.

(iii) The identifying material must be submitted through the electronic registration system, and all of the Start Printed Page 59000 identifying material that was published on a particular date must be contained in the same electronic file. The files must be submitted in PDF format, they must be assembled in an orderly form, and each file must be uploaded to the electronic registration system as an individual electronic file ( i.e., not .zip files). The file size for each uploaded file must not exceed 500 megabytes, but files may be compressed to comply with this requirement.

(7) Special relief. In an exceptional case, the Copyright Office may waive the online filing requirement set forth in paragraph (m)(5) of this section or may grant special relief from the deposit requirement under § 202.20(d) of this chapter, subject to such conditions as the Associate Register of Copyrights and Director of the Office of Registration Policy and Practice may impose on the applicant.

(r) The scope of a group registration. When the Office issues a group registration under paragraph (d), (e), or (f) of this section, the registration covers each issue in the group and each issue is registered as a separate work or a separate collective work (as the case may be). When the Office issues a group registration under paragraphs (c), (g), (h), (i), (j), (k), or (o) of this section, the registration covers each work in the group and each work is registered as a separate work. When the Office issues a group registration under paragraph (m) of this section, the registration covers each update in the group, and each update is registered as a separate collective work. For purposes of registration, the group as a whole is not considered a compilation, a collective work, or a derivative work under section 101, 103(b), or 504(c)(1) of title 17 of the United States Code.

Shira Perlmutter,

Approved by:

Carla D. Hayden,

Librarian of Congress.

1. 17 U.S.C. 408(c)(1) .

2. Id.

3. See generally 37 CFR 202.3(b)(5) , 202.4 .

4. Id. at 202.3(b)(5), 202.4(c)-(k), (o).

5. See 89 FR 311 , 311-12 (Jan. 3, 2024).

6. U.S. Copyright Office, Copyright Protection for Press Publishers (June 2022), https://copyright.gov/policy/publishersprotections/202206-Publishers-Protections-Study.pdf .

7. See 89 FR 311 , 312 .

8. Id. at 311. The final rule defines a “news website” as “a website that is designed to be a primary source of written information on current events, either local, national, or international in scope, that contains a broad range of news on all subjects and activities and is not limited to any specific subject matter.” 37 CFR 202.4(m)(1)(i) .

9. Because the Office will not examine each component work within the collective work, the copyright claimant bears the burden of proving that it owns the individual component works claimed in the submission.

10. A “collective work” is a type of compilation. See 17 U.S.C. 101 . A “compilation” is “a work formed by the collection and assembling of preexisting materials or of data that are selected, coordinated, or arranged in such a way that the resulting work as a whole constitutes an original work of authorship.” Id.

11. As noted in the NPRM, “in appropriate circumstances, the Office may waive the online filing requirement, subject to the conditions the Associate Register of Copyrights and Director of the Office of Registration Policy and Practice may impose.” 89 FR 311 , 316 n.55.

12. The Office also received a letter from several organizations reflecting their collective support for finalizing the rulemaking in a timely manner and in-line edits to the Office's proposed regulatory language. Letter from Ass'n of Am. Publishers et al. to Suzanne Wilson, Gen. Counsel and Assoc. Register of Copyrights (Apr. 4, 2024), https://www.copyright.gov/rulemaking/newswebsite/Association-of-American-Publishers-et-al%E2%80%93Letter-to-Copyright-Office.pdf .

13. See Am. Ass'n of Independent Music, Ass'n of Am. Publishers, Inc, and Recording Industry Ass'n of Am., Inc. (“A2IM, AAP, & RIAA”) Comment at 2 (“Commenters express no position on the primary focus of the NPRM—whether the Office should create a new group registration option for frequently updated news websites—or on the details of how such an option should be implemented.”).

14. See generally Nat'l Writers Union, Nat'l Press Photographers Ass'n, Nat'l Ass'n of Sci. Writers (“NWU, NPPA, & NASW”) Comment; Gordon Firemark 2 Comment.

15. A handful of commenters also proposed that the Office should adopt the NPRM immediately, as an interim rule. See, e.g., Copyright All. Comment at 11; Nat'l Pub. Radio (“NPR”) Comment at 3-5; News Media All. (“NMA”) Comment at 2.

16. Am. Bar Ass'n Section of Intell. Prop. L. (“ABA-IPL”) Comment at 4.

17. 89 FR at 311-12 (noting that “[m]ore than eight in ten Americans get news from digital devices, and, as of 2021, more than half prefer digital platforms to access news”).

18. Id. (citing Newspaper Association of America Comments at 12-18, Submitted in Response to July 15, 2009 Notice of Proposed Rulemaking, Mandatory Deposit of Published Electronic Works Available Only Online, U.S. Copyright Office Dkt. No. 2009-3 (Aug. 31, 2009) (emphasis omitted), https://www.copyright.gov/rulemaking/online-only/comments/naa.pdf ).

19. 37 CFR 202.4(e) . The Office's definition of newspapers is based on the Library of Congress's collection policy definition. Library of Congress, Collections Policy Statements: Newspapers—United States 1 (Sept. 2023), https://www.loc.gov/acq/devpol/neu.pdf .

20. NWU, NPPA, & NASW Comment at 12-13; Gordon Firemark 2 Comment (asserting that “the proposed regulation is not Content Neutral, as required under the First Amendment”).

21. Arkansas Writers Project, 481 U.S. at 234.

22. NWU, NPPA, & NASW Comment at 12-13.

23. Gordon Firemark 2 Comment.

24. Id. (citing Iancu v. Brunetti, 139 S. Ct. 2294 (2019), and Matal v. Tam, 582 U.S. 218 (2017)).

25. Reed v. Town of Gilbert, 576 U.S. 155, 163 (2015).

26. Sable Commc'ns of Cal. v. FCC, 492 U.S. 115, 126 (1989).

27. Reed, 576 U.S. at 164 (internal quotes omitted).

28. Leathers v. Medlock, 499 U.S. 439, 452-53 (1991) (citing Mabee v. White Plains Publ'g Co., 327 U.S. 178 (1946), and Oklahoma Press Publ'g Co. v. Walling, 327 U.S. 186 (1946)).

29. Arkansas Writers Project, 481 U.S. at 229 (finding the tax scheme impermissibly targets a small group of the press because “the magazine exemption means that only a few Arkansas magazines pay any sales tax”).

30. Arkansas Writers Project, 481 U.S. at 229-30.

31. 37 CFR 202.3(b)(2)(i)(A) .

32. See generally id. at 202.4.

33. Vidal v. Elster, No. 22-704, slip op. at 1 (2024).

34. Id.

35. Id. at 4 (2024) (quoting National Institute of Family and Life Advocates v. Becerra, 585 U.S. 755, 766 (2018)).

36. Id. (2024) (quoting Rosenberger v. Rector and Visitors of Univ. of Va., 515 U. S. 819, 829 (1995)).

37. Id. at 6.

38. Id. at 12.

39. 17 U.S.C. 408(c)(1) (emphasis added).

40. Leathers, 499 U.S. at 452 (quoting Regan v. Taxation with Representation, 461 U.S. 540, 549 (1983)).

41. See Gordon Firemark 2 Comment (citing Iancu v. Brunetti, 139 S. Ct. 2294 (2019), and Matal v. Tam, 582 U.S. 218 (2017)).

42. See, e.g., 85 FR 37341 , 37345 (June 22, 2020) (final rule for group registration of short online literary works); 83 FR 61546 , 61546-48 (Nov. 30, 2018) (final rule for group registration of newsletters and serials); 82 FR 29410 , 29410-11 (June 29, 2017) (final rule for group registration of contributions to periodicals).

43. See ABA-IPL Comment at 2; Am. Intell. Prop. L. Ass'n (“AIPLA”) Comment at 1 (“We encourage the Office to reconsider [the definition of `news website'] and clarify the final clause—`not limited to any specific subject matter'—which could be construed as excluding news websites with an industry-specific focus ( e.g., wired.com), and thus unnecessarily limiting access to this group registration option.”); Copyright All. Comment at 4 (“We urge deletion of the phrase `. . . on all subjects and activities and is not limited to any specific subject matter' in the proposed rule . . . .”); Harvard Bus. Publ'g (“HBP”) Comment; Nat'l Ass'n of Broad. (“NAB”) Comment at 3; NWU, NPPA, & NASW Comment at 12-13; NMA Comment at 8; The Authors Guild Comment at 2; see also Letter from Ass'n of Am. Publishers et al. to Suzanne Wilson, Gen. Counsel and Assoc. Register of Copyrights (Apr. 4, 2024).

44. ABA-IPL Comment at 2.

45. HBP Comment.

46. The Authors Guild Comment at 1-2.

47. John Murphy Comment; The Authors Guild Comment at 2 (arguing that “making eligibility determinations based on the substantive content of the materials submitted for registration . . . goes well beyond the Office's ordinary examination process”).

48. Gordon Firemark 1 Comment; see NWU, NPPA, & NASW at 12-13; Brenda Ulrich Comment; John Murphy Comment.

49. 37 CFR 202.4(e)(1) .

50. 82 FR 51369 , 51371 (Nov. 6, 2017).

51. 37 CFR 202.4(f)(1)(i) .

52. Id. at 202.4(e)(1) (“Newspapers are intended either for the general public or for a particular ethnic, cultural, or national group”).

53. The Authors Guild Comment at 1-2.

54. Cf. 37 CFR 202.4(f)(1)(i) (designed for newsletters that “contain news or information that is chiefly of interest to a special group”).

55. Group registration of serials provides a registration option for serial issues within a three-month period that meet the eligibility requirements for that option. Id. at 202.4(d)(1). Group registration of newsletters provides an option for registering a group of newsletters published within a one-month period. Id. at 202.4(f)(1).

56. Copyright All. Comment at 6; NAB Comment at 4; NMA Comment at 10.

57. The Authors Guild Comment at 2; Copyright All. Comment at 6; NAB Comment at 4.

58. U.S. Copyright Office, Compendium of U.S. Copyright Office Practices sec. 722 (3d ed. 2021) (“ Compendium (Third) ”).

59. Id.

60. AIPLA Comment at 1-2.

61. Id.

62. In the NPRM, the Office also noted that when a website is registered as a compilation, the statute provides that the copyright owner may seek only one award of statutory damages for infringement of the compilation as a whole—rather than a separate award for each individual work that appears on the website—even if the defendant infringed all of the works covered by the registration. 17 U.S.C. 504(c)(1) (“For the purposes of this subsection, all the parts of a compilation or derivative work constitute one work.”). Some commenters urged the Office to acknowledge and adopt the “ `independent economic value' test to determine when copyrighted material constitutes a separate `work' for the purpose of determining eligibility for statutory damages.” A2IM, AAP, & RIAA Comment at 2-3; Copyright All. Comment at 8; NAB Comment at 6-8. Acknowledging that the NPRM correctly states “that the group registration option will extend to individual works that make up the collective work if they are fully owned by the applicant,” NMA asked the Office to confirm that its statement “do[es] not reflect a substantive opinion on eligibility for statutory damages.” NMA Comment at 11-12. The Office stands by its restatement of section 504(c)(1) and declines to address the matter further in this rulemaking. See H.R. Rep. No. 94-1476, at 162 (1976), reprinted in 1976 U.S.C.C.A.N. 5659, 5770 (“Subsection (c)(1) makes clear, however, that, although they are regarded as independent works for other purposes, `all the parts of a compilation or derivative work constitute one work' for this purpose.”).

63. NPR Comment at 7.

64. 37 CFR 202.4(m)(1)(i) (emphasis added).

65. Compendium (Third) sec. 1002.2.

66. Id.

67. See 37 CFR 202.1(a) .

68. John Murphy Comment; see NPR Comment at 5 (“[T]he office should further relax the frequency”); NWU, NPPA, & NASW Comment at 16-17.

69. NPR Comment at 5.

70. NWU, NPPA, & NASW Comment at 16.

71. The Authors Guild Comment at 3; NWU, NPPA, & NASW Comment at 11; NMA Comment at 11; AIPLA Comment at 2; Letter from Ass'n of Am. Publishers et al. to Suzanne Wilson, Gen. Counsel and Assoc. Register of Copyrights (Apr. 4, 2024).

72. The Authors Guild Comment at 3; NWU, NPPA, & NASW Comment at 11.

73. NMA Comment at 11; AIPLA Comment at 2 (“[W]e see no clear policy reason to disfavor registration of copyrights acquired through other means ( e.g., by assignment).”).

74. Compendium (Third) sec. 620.4.

75. ABA-IPL Comment at 3; AIPLA Comment at 2; Copyright All. Comment at 6-7; NAB Comment at 5; NMA Comment at 7; The Authors Guild Comment at 4.

76. The Authors Guild Comment at 4.

77. Id.

78. Note, however, the Office will not certify the accuracy of such additional information based on the identifying material deposited.

79. Copyright All. Comment at 7.

80. NMA Comment at 7.

81. 89 FR at 316.

82. Id.

83. Id.

84. NMA Comment at 11.

85. 37 CFR 202.4(m)(6)(i) (emphasis added); see also 89 FR at 316 (“Each PDF must show how the home page appeared at a specific point during each day of the calendar month when new updates were published on the site.”).

86. Copyright Alliance Comment at 10-11; NAB Comment at 4-5; NMA Comment at 11. See also Letter from Ass'n of Am. Publishers et al. to Suzanne Wilson, Gen. Counsel and Assoc. Register of Copyrights at App. at 2 (Apr. 4, 2024) (proposing regulatory language altering the deposit requirement when “a complete copy is technically unfeasible or unreadable due to the size or continuous nature of the home page”); Nexstar Media Group Inc. Comment (stating that Nexstar “would like to see even more modification of the requirements for article submission, so that each local television station or other news site would not be required to have dedicated staff purely for depositing copyrighted materials, which may be updated several times per day”).

87. NAB Comment at 5.

88. Id.

89. Copyright All. Comment at 10-11.

90. NMA Comment at 11.

91. 89 FR at 316.

92. NWU, NPPA, & NASW Comment at 17-20.

93. Id.

94. Id.

95. Id.; see also id. at 20 (proposing “submission of `a file or set of files linked from a master file listing in structured form the text files on the site added or modified during the time period covered by the application, including the URL and the date each file was added to the site or most recently modified' ”).

96. Id. at 17, 20. NWU, NPPA, and NASW asserted that “the `sitemap.xml' standard has been widely accepted and adopted by website publishers, web publishing platforms, and developers of content management systems (CMSs).” Id. at 17-18.

97. See 17 U.S.C. 410(a) ; Compendium (Third) sec. 204.3 (“[D]eposit copy(ies) should be clear and should contain all the authorship that the applicant intends to register.”). This finding is bolstered by the examples cited in NWU, NPPA, and NASW's comment, which do not provide any information that would allow the examiner to determine any copyrightability of the collective work. See NWU, NPPA, & NASW Comment at 18 nn.19-22; id. at 19 nn.23-26.

98. See H.R. Rep. No. 94-1476, at 153 (1976), reprinted in 1976 U.S.C.C.A.N. 5659, 5769 (“As a general rule the deposit of more than a tear sheet or similar fraction of a collective work is needed to identify the contribution properly and to show the form in which it was published.”).

99. 89 FR at 316.

100. See NWU, NPPA, & NASW Comment at 20 (suggesting that sitemaps “could be used immediately in manual Copyright Office work flow but would also lend themselves to efficiencies through automated parsing”).

101. Erik Gottlieb Comment.

102. Copyright All. Comment at 6; NMA Comment at 10; The Authors Guild Comment at 2. See also Letter from Ass'n of Am. Publishers et al. to Suzanne Wilson, Gen. Counsel and Assoc. Register of Copyrights at 1 & App. at 2 (Apr. 4, 2024) (proposing the Office “include[e] mobile app content in the scope of the rule”). The Office also received a comment from Port. Prerogative Club, suggesting that the Office “evaluate whether native [version control systems (“VCS”)] files would satisfy [the Office's] internal requirements for deposit copies.” Port. Prerogative Club Comment at 2. The Office currently does not accept this file format, but will revisit file formats as part of its ongoing work in developing the Enterprise Copyright System.

103. Erik Gottlieb Comment.

104. NMA Comment at App. at 16 (proposing regulatory language). See Copyright All. Comment at 6; NMA Comment at 10; The Authors Guild Comment at 2. See also Letter from Ass'n of Am. Publishers et al. to Suzanne Wilson, Gen. Counsel and Assoc. Register of Copyrights at 1 & App. at 2 (Apr. 4, 2024) (proposing the Office “includ[e] mobile app content in the scope of the rule”).

105. Copyright All. Comment at 6; The Authors Guild Comment at 2.

106. Copyright All. Comment at 6.

107. Id. (noting that “news content on an app is already organized and contained in an interconnected and uniform ecosystem, much like a website”); NMA Comment at 10 (stating that app screenshots serve the same “identifying function as URLs”).

108. NMA Comment at 10.

109. See 89 FR at 313 (“[T]he organization and arrangement show in a PDF package may vary depending on whether it depicts the website as it would appear on a desktop computer, a mobile phone or other electronic device.”). But cf. ABA-IPL Comment at 4 (“The Section is aware of no substantive difference between what is published at a URL and what is published on an app.”).

110. ABA-IPL Comment at 4-5.

111. Id. at 4.

112. UM-Library Comment at 1-2.

113. 89 FR at 313; see also eCO Acceptable File Types, U.S. Copyright Office, https://www.copyright.gov/eco/help-file-types.html (last visited July 5, 2024) (listing acceptable file formats).

114. For example, the Office is researching the web archive file format (“WARC”) that is utilized by the Library of Congress' Web Archiving Team. Research has shown that there are many publicly available options for adapting websites in the WARC format, including through internet browser extensions.

115. 17 U.S.C. 408(c)(1) ; see also 89 FR at 311 (discussing identifying material).

116. H.R. Rep. No. 94-1496, at 154 (1976), reprinted in 1976 U.S.C.C.A.N. 5659, 5770.

117. See 89 FR at 313, 316 (discussing how depositing complete copies of websites poses difficulties for applicants and the Office).

118. Id. at 316.

119. Id.

120. See Letter from Ass'n of Am. Publishers et al. to Suzanne Wilson, Gen. Counsel and Assoc. Register of Copyrights (Apr. 4, 2024); Copyright All. Comment at 11.

121. H.R. Rep. No. 79-1980, at 260 (1946). See 5 U.S.C. 553(d) (30-day notice not required where agency finds good cause).

[ FR Doc. 2024-15880 Filed 7-19-24; 8:45 am]

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