(a) Wiley reads “lawfully made under this title” to impose a geo-
graphical limitation that prevents §109(a)’s doctrine from applying to Wiley Asia’s books. Kirtsaeng, however, reads the phrase as impos- ing the non-geographical limitation made “in accordance with” or “in compliance with” the Copyright Act, which would permit the doctrine to apply to copies manufactured abroad with the copyright owner’s permission.
(b) Section 109(a)’s language, its context, and the “first sale” doc- trine’s common-law history favor Kirtsaeng’s reading