The 1976 Act also includes the first sale doctrine, another long-time judicially applied limit on copyright.74 The first sale doctrine gives copyright holders the right to control the first sale or disposition of a copy, but does not permit copyright holders to
restrict or control the resale or transfer of the copy.75
One of the major changes to the 1976 Act from its predecessor, the 1909 Act,76 was the addition of § 111.77 Section 111 creates a compulsory license for cable companies’ retransmission of broadcast TV.78 Cable companies can retransmit local broadcasts without permission from the broadcasters so long as cable companies pay royalties to the broadcasters.79 While some stakeholders argue that § 111 is broad enough to encompass services like Aereo and FilmOn,80 the Copyright Office does not agree and has opposed creating a compulsory licensing scheme for such services.81