The purpose of the Copyright Act of 1976 is to recognize the value of the copyright to the copyright holder, to encourage creativity, and to promote socially desirable works that augment United States culture. But how valuable is a copyright when it becomes almost impossible for a plaintiff to successfully sue for copyright infringement? Increasing the difficulty in enforcing a copyright lessens the value of the copyright--which works against the very purpose of the Copyright Act. Recent developments in federal case law have indeed made it harder than ever for a plaintiff copyright holder to successfully enforce his copyright. A trend arising in the courts may result in a higher pleading standard for copyright plaintiffs, which would lead to more copyright cases being dismissed at the pleading stage.