Home Publishers DC So now who owns the Comics Code's historical archives?

So now who owns the Comics Code's historical archives?


With the Comics Code finally rendered inactive, people are starting to wonder about what went on in that abandoned-looking mansion up on the hill. Vaneta Rogers made like an actual reporter and called people and put things together to reveal that after some snooping around, it looked like the Code hadn’t really been around for over a year:

But Newsarama hasn’t been able to locate any evidence that the organization was functioning since 2009. And Archie Comics has indicated that it wasn’t actually submitting comics for approval to the Comics Magazine Association of America, which oversaw the Code.

Retailer Joe Field suggests that the last few publishers who used to Code seal – Archie and DC — just put it on the cover because they were up on their dues:

“It used to be that everything had to go through the Code, be stamped and sealed, and then could be sent off to the printer,” Field said. “I think that, over the last number of years — and it’s kind of obvious, because there were things that wound up with a Code seal that would have never gotten through the code — if a company was up on their dues, they could put the Code on their book.”

Rogers tracked down the last person who seemed to know anything about running the Code, Holly Munter Koenig, who worked for the Kellen Company, a trade organization management firm which had been handling the business of the Comics Magazine Association of America, the organization which functioned to administer the Code and, supposedly, render other services to the comics industry. Koenig said all Code matters should be referred to DC Comics; a DC spokesperson said:

A spokesperson for DC, although not offering a statement on the record, confirmed that its dues were paid to the CMAA through December 2010 and that comics were submitted until that time. DC uses the Code approval logo on comics like Tiny Titans, Superman, and Batman, with the seal appearing on the covers of those titles published as recently as December 2010. At the time of this article, the publisher had not fulfilled a request for information on how those comics were submitted and to whom.

Which brings us up to another matter? If the CMAA had quietly faded away over the last few years, what happened to their archives, a treasure trove of information on the history of comics? We received an alarmed letter from reader Sean Howe who lamented the potential loss of this material:

Unfortunately, as the Comic Magazine Association of America quietly dissolves, it also carries its own history down the drain. Last year, in the course of researching a book, I tried without success to locate the files of the CMAA, which had been maintained since 1948 and were accessible as of the 1990s. Representatives at DC, Archie, and Marvel were unable to answer my questions about where the files might have ended up, although I did receive a response from a former CMAA representative. In regard to my question of who might now be safeguarding the documents, she wrote,
“There really is no one. Legally, none of the old documents of the organization had to be kept. Much of it was kept in Michael Silberkleit’s office up in Archie, but as you now know, sadly, he passed on. Not sure what they would have done with the old files.”

The records of Josette Frank and the Child Study Association of America—which had challenged the comic-book scare of the late 1940—had been donated to the CMAA years ago. Now they have vanished, along with detailed notes on industry-wide meetings throughout the 1950s, 1960s, 1970s, and 1980s among Jack Liebowitz, Stan Lee, Carmine Infantino, John Goldwater, and others.

It seems very possible that these traces of history will soon (if they haven’t already) wind up in the dumpsters of corporate offices of Time Warner or Disney. The industry’s lack of interest in its own heritage is distressing. Do you suppose anything can be done?

So who has these papers…if they even still exist? Today, Mark Seifert dug a bit more into the Code’s history, with a look at their tax returns (it was a non-profit organization) and a brief exchange with Koenig, who writes:

I’ll say something personal–there were a lot of long time, hard working supporters of the association. It wasn’t just about the Code. Many of these remarkable people are now retired or have passed away. The CMAA was fortunate to have Ski (Marvel) amongst its leadership for years… and Paul Levitz, who very respectfully kept the organization together long after its founders passed away.

The Association belonged to the industry, not Kellen, but we definitely cared a lot about its existence.

And then, the money quote for Howe’s question:

Koenig says that the CMAA’s historical records and documentation have been forwarded to DC’s legal department. Given the important role the CMAA has played in our business, one hopes that DC’s lawyers will eventually allow historians access to what must be a fascinating look at our industry’s history.

She says that the records have been in storage and are just now being shipped to DC. While Paul Levitz–the person we imagine would be most concerned with these archives at DC — is no longer running DC, one hopes that someone there has an idea of how valuable these archives could be. Another one of our correspondents suggesting donating them to the Ohio State University comics archives. Or will we end up with….


  1. Heidi — We had some discussion over at BC re getting material like this to tOSU or MSU, but here’s what I wonder about that: We’re at a point in our history where there are pros, retired pros, and interested fan historians who as a group are probably currently in a better position to examine such materials with a knowledgeable eye than academia might be currently (though that may well change in a decade or two). How accessible are the major university collections to non-academics? (and I’m not making any implication here, just asking the question)

    I do know that many interested people have been able to examine Ditko’s AF #15 art at the Library of Congress, and that the LoC also has a collection of Wertham’s papers, so that might be a possible home for such materials as well.

  2. For all those folks interested in Code lore, below is a link to scans I made and in 2009 posted on “The Comics Journal” Web site. The 1950s-era Code material consists of retail stickers and the Code’s then-current tri-fold informational brochure.

    Interestingly enough, these originally belonged to super-fan Dr. Jerry Bails, who included them amongst some comics-related papers and fanzines I bought from him during the 1980s.


  3. Mark: In my experience university libraries are usually thrilled with helping people access archives. It’s their job, after all. The Privileges Desk is usually very generous to sincere researchers, even if they don’t have established bona fides. …I make comics for a living and have reading privileges at Pierpont Morgan and Bienecke, mostly just because I asked nicely. So a comics professional should be welcomed with open arms if he wants to look at a comics industry collection.

  4. The archives have to be stored somewhere and conserved. Libraries and museums are the best places for such requirements. (Museums more so if realia is involved.)

    Academic institutions are accommodating to researchers, and most do not require much certification beyond identification and registration. If the library has a large collection, requiring multiple visits, you can usually purchase a temporary library card. (Check the university library’s website. Most have a written policy posted.)

    The Library of Congress is the best repository, given the scope of their comics collections.
    Perhaps the Swann Foundation could assist.

    LoC also has been aggressive in digitizing their holdings.

  5. As a Michigan State grad who spent a lot of time during and after my undergrad years in the library’s special comics collection, I can attest that Randall Scott is super open to people not associated with academia coming in to see the collection. Also: all my interaction’s with Lucy’s team at OSU had given me a similar impression. Also: I just had the pleasure of meeting U of Minnesota librarian Meredith Gillies who’s building a big comics collection there and is really big on community involvement and sharing with researchers of all stripes. So I’d say placing this stuff in a proper university library is a great way to go.

    That said, if DC really are the ones who will find themselves in possession of the code’s assets, they have a pretty killer library themselves, so they may want to keep it in house.

    Of course, all of this is moot if nobody finds the stuff.

  6. I say we gather all the papers in the town square and have a good old fashioned code burning. Everyone bring your code-approved comics to add to the bonfire.

  7. I’m not to sure what documents are we talking about. When I sent books out to the code they where just photocopies of the comic books, we dated the files and sent them out, We put the seal on the comics Unless something came back, which was very very few things.

  8. I have question– if the CMAA was a separate, non-profit organization, why should the legal department of a corporation be taking possession of its papers?

    I’m not surprised that DC legal would *want* to take possession of these papers, if only to vet them for any potential liability or embarassment. But what right have they taken this possession? And do any of us think that, once the legal department of a publisher with a profit interest in protecting its brand gets hold of these papers that there is much chance they will be made available again?

  9. Personally, I’d love to see those archives stay in NYC. I’m a librarian at Columbia, and we are beginning to acquire comics archives for our Rare Book and Manuscript Library.

    Whether they go to Columbia, or Ohio, or Michigan, however, you should know that academic archives are open to all scholars, not just those at the institution.

  10. When I was at the CMAA offices in the mid-1990s doing research for my book on the history of the code, they had all sorts of records; minutes of meetings, correspondence, proposed revisions to the code that were never made. And Holly told me that the records in the office were just the tip of the iceberg. Such a collection is a valuable historical record; I’d hate to see it end up in the hands of corporate America, which certainly has obligation to provide access, especially to material that might not cast DC in a favorable light.

  11. Mark,
    I’m the curator at the Ohio State Univ. Billy Ireland Cartoon Library & Museum. The materials in our collection are open to all researchers and fans, even those not affiliated with a specific university. Comics pros, fan historians, journalists, etc. are all welcome. I agree whole-heartedly that these archives should be preserved and made available to researchers. So much of comics history has already been lost. It would be a shame if these valuable papers disappeared too.

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