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RBC, while I appreciate having your lawyer come down here and repeat the same advice he gave you, it is my feeling that he has missed the most important point.
You purchased outright the content from RBC. You became the custodian of records for that content, and as such, accepted all the legal rights and liablities that come with it.
You own lawyer admits that "old RBC" perhaps didn't fulfill it's obligations under the law the provide valid and usable 2257 information to all license holders. I understand that "current RBC" doesn't want to spend man hours and make efforts to provide the documentation now. I also understand the law says you have to.
Isis as a company doesn't appear to have any obligations in this situation, as you have taken over the responsbility of record keeping and such for all of these images. You became the owners of the images, and took the 2257 job over at that point. had you only purchased resale rights and allowed Isis to remain the primary producer on these images, they would be responsible for 5 years after they close (or could be 7 now...) to maintain a custodian of records office. You as a secondary producer would only be required to maintain the records for sales going forward (your clients).
The difference lies in what you purchased and the responsilbities that come with that purchase, even if you were not clearly aware of them at the time.
Your lawyer has provided you advice that, IMHO, will not only mean that many webmasters will not be able to use your content going forward, but also that those same webmasters going forward won't want to do any business with you in the future. Further, it is my feeling that failure to provide this documentation willingly without strings may leave you in the position of yourselves being in a position of being in violations of the DOJ guidelines.
I wish you luck with the road you have chosen. It makes it much easier to chose the road I will take.
Alex
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