Nor is there any other writing that would support the check's transfer of copyrights. See Johnson v. Tuff–n–Rumble Mgmt., Inc., No. 99–1374, 2000 WL 1145748, at *6 (E.D.La. Aug. 14, 2000) (holding § 204(a)'s writing requirement satisfied by check stating “assignment of [plaintiff's] copyrights to [defendant] agreement dated June 17, 1997,” where there was also an unsigned contract referring to check). We thus agree that IRP cannot show that the royalties check was a transfer of copyright.

Agreement contains language that could have even arguably conveyed [the plaintiff's] renewal rights"), Playboy Enters., Inc. v. Dumas, 53 F.3d 549, 564 (2d Cir. 1995) (affirming district court's holding that check legend reading "payee acknowledges payment in full for the assignment to Playboy Enterprises, Inc. of all right, title, and interest in and to the following items: [a description of a painting followed]" was insufficient to transfer copyright under § 204(a) because it did not include the word "copyright" and because there was no evidence of an existing prior agreement (brackets in original)), and Museum Boutique Intercontinental, Ltd. v. Picasso, 880 F. Supp. 153, 162 & 162 n. 11 (S.D.N.Y 1995) (noting that two checks offered to prove the existence of a prior oral licensing agreement for purposes of section 204(a) did "not contain any explanatory notations besides 'Picasso royalties,'" and so were "not convincing proof, to say the least, of the alleged oral agreement"), with Johnson v. Tuff-N-Rumble Mgmt., Inc., 2000 WL 1145748, at *6-7 (E.D. La. Aug. 14, 2000) (holding that endorsed check complied with section 204(a) when check legend stated it was for "assignment of [the plaintiff's] copyrights to [the defendant] agreement dated June 17, 1997," and where there was an unsigned contract dated June 17, 1997 that referred to the check), and Dean v. Burrows, 732 F. Supp. 816, 818-19, 823 (E.D. Tenn. 1989) (holding that check bearing only notation for "mold designs and molds" satisfied section 204(a) when written transfer agreement in copyright owner's handwriting was prepared the same month the check was issued and was later recorded in the Copyright Office). Looking at the check in this case on its own without extrinsic evidence (as Hacienda's summary judgment motion presents the issue), the Court concludes that this case has more in common with the cases rejecting assignment.