Despite its appeal as a solution to the overprotection problem, a reintroduction of formalities may be both legally and politically infeasible. Although Sprigman suggests that a modern formalities scheme [*712] could be developed within the framework mandated by the Berne Convention, n80 his analysis is uncertain and goes against the commonly understood goal of the modern Convention. n81 Moreover, reintroducing formalities hurts independent and infrequent creators, who may want to benefit from copyright protections but who lack the business and financial resources to