that “infringement ‘commences’ for the purposes of [determining whether infringement commences before a copyright’s registration] when the first act in a series of acts constituting continuing infringement occurs.” Johnson v. Jones, 149 F.3d 494, 506 (6th Cir.1998). Under 17 U.S.C. § 412, a plaintiff may not recover statutory damages or attorney’s fees for any infringement “commenced” before the effective date of a copyright’s registration. The courts have held, based on the provision’s text, legislative history, and purpose, that a plaintiff may not recover statutory damages and attorney’s fees for infringement occurring after registration if that infringement is part of an ongoing series of infringing acts and the first act occurred before registration. See, e.g., id. at 505-06 (<HOLDING>); Singh v. Famous Overseas, Inc., 680 F.Supp.
holding that the university of colorado is an arm of the state for purposes of sovereign immunity holding that all claims arising from the same employment relationship constitute the same transaction or series of transactions for claim preclusion purposes holding that the purposes of section 412 would be thwarted by holding that infringement is commenced for the purposes of  412 each time an infringer commits another in an ongoing series of infringing acts and citing cases holding that a county is not an arm of the state for purposes of the eleventh amendment holding that the historical background of the decision particularly if it reveals a series of official actions taken for invidious purposes is significant in determining discriminatory intent