On April 1, the Copyright Alliance submitted comments in response to the U.S. Copyright Office’s notice of proposed rulemaking regarding the creation of a new Group Registration for Two-Dimensional Artwork (GR2D). The comments detail serious concerns with the NPRM, requesting the Office to address these issues for the group registration option before implementing the rule, including discussion on registration examiner actions and correspondence, the rule’s ten-work limit, and the thirty-day time period, among other issues. The comments also raise concerns surrounding the Office’s registration modernization process.