The third step required for obtaining a defendable copyright is to print upon the title-page or the page immediately following it in each copy of the book the statutory notice of copyright. The form of this notice must be either "Entered according to Act of Congress, in the year ----, by A. B., in the office of the Librarian of Congress, at Washington;" or, "Copyright, 19----, by A. B." The name printed in this notice must be the real, legal name of the proprietor of the copyright, and must be the same as that in which the entry of title has been made; the date, also, must be the year date of the record of the filing of the title-page. A judicial decision is on record to the effect that printing the year date in this notice one year later than the date of actual recording of title barred the defence of the copyright. A penalty of $100 is imposed on "every person who shall insert or impress such notice, _or words of the same purport_ in or upon any book ... whether subject to copyright or otherwise, for which he has not obtained a copyright." An American author may obtain for his book copyright protection in Great Britain, by a compliance with the official instructions as to publication, deposit of copies and registration. The protection, under English law, dates from the day of _first_ publication, but such first publication must be on English territory, and registration may follow, but cannot precede publication. The term of protection in the United States, on the contrary, dates from the day of registration of title in our Copyright Office, which must precede publication, and be followed by deposit of copies made "not later than the day of publication thereof in this or any foreign country." The point to guard, therefore, is _simultaneous publication_ in this country and in Great Britain. Registration in England is a secondary matter. As stated in the official circulars of instructions issued by the English Copyright Office, "Copyright is created by the statute, and does not depend upon registration, which is permissive only, and not compulsory, but no proprietor of copyright in any book can take any proceedings in respect of any infringement of his copyright unless he has, before commencing his proceedings, registered his book." Under existing legal conditions, in order to secure valid copyright on a book in this country and in England, the following steps should be taken, and in the order stated. 1. Record title in the United States Copyright Office. 2. Print book from type set within the limits of the United States. 3. Deposit two copies of such book in the United States Copyright Office. 4. Send sufficient copies to London to _a._ Place copies on sale and take such usual steps as are understood, under English law, to constitute "publication" on a prearranged day, on which same day the book is published in the United States.