The elimination of formalities in U.S. copyright law began with the Copyright Act of 1909, which made publication with notice of copyright the condition for protection. n65 The Copyright Act of 1976 eliminated publication with notice as a prerequisite to protection, extending copyright protection to the moment of creation. n66 Under the 1976 Act, copyright owners who published without notice still risked losing copyright protection -- until the United States acceded to the Berne Convention, which made the notice formality optional. n67 The 1976 Act and subsequent amendments also adopted a unitary term of copyright protection, eliminating the renewal formality. n68