Agency and Other Filings

As we advocate for policies that promote and preserve the value of copyright and protect the rights of creators and copyright owners, the Copyright Alliance regularly files comments with the U.S. Copyright Office and government agencies on different copyright policies studies and regulations. When we file comments, we encourage strong and effective copyright protections that will benefit the creative community and the copyright system more generally. When necessary, the Copyright Alliance conducts surveys of our creator members in order to collect data on important copyright issues. Some examples of comments we have filed with the U.S. Copyright Office and other government agencies include, but are not limited to, State Sovereign Immunity, Registration Modernization, Online Publication, Artificial Intelligence, and the Digital Millennium Copyright Act (DMCA).

March 7, 2022

Remitter Payment Options and Deposit Account Requirements

Summary:

The Copyright Alliance submitted comments to the U.S. Copyright Office in response to a notice of proposed rulemaking to amend its regulations governing remitter payments for Office services and requirements for maintaining a deposit account.

February 22, 2022

Copyright Claims Board: Active Proceedings and Evidence (Reply Comments)

Summary:

The Copyright Alliance (joined by 18 other organizations) submitted reply comments to the U.S. Copyright Office in response to a notice of proposed rulemaking regarding procedures governing active proceedings before the Copyright Claims Board and post-determination procedures.

February 18, 2022

Copyright Claims Board: Law Students and Business Entities Representations Reply Comments

Summary:

The Copyright Alliance (joined by 19 other organizations) submitted reply comments to the U.S. Copyright Office’s notice of proposed rulemaking regarding procedures governing the appearance of law student representatives and employees of business entities in proceedings before the Copyright Claims Board (CCB).

February 7, 2022

Copyright Claims Board: Active Proceedings and Evidence

Summary:

The Copyright Alliance (joined by 19 other organizations) submitted comments to the U.S. Copyright Office in response to a notice of proposed rulemaking regarding procedures governing active proceedings before the Copyright Claims Board and post-determination procedures.

February 3, 2022

Copyright Claims Board: Law Students and Business Entities Representations Initial Comments

Summary:

The Copyright Alliance (joined by 19 other organizations) submitted comments to the U.S. Copyright Office in response to its Notice of Proposed Rulemaking regarding procedures governing the appearance of law student representatives and employees of business entities in proceedings before the Copyright Claims Board (CCB). The comments suggest that the Office broaden, clarify, and delay various definitions and requirements to increase law school clinic participation in CCB representations and to facilitate streamlined, efficient processes for business entities representations.

January 31, 2022

Study To Advance a More Productive Tech Economy

Summary:

The Copyright Alliance submitted comments to the National Institute of Standards and Technology (NIST) in response to a Notice of Inquiry regarding its public study seeking comments to help identify, understand, refine, and guide the development of the current and future state of emerging technologies. Focusing on the intersection of copyright law and artificial intelligence (AI), the comments explain that AI is a profound technology that will implicate difficult questions as it relates to copyright. The comments identify three main principles that must form the basis of the copyright and AI discussion: (1) A respect for copyright that does not prioritize the interests of those developing AI systems over the rights and interests of creators and copyright owners, (2) Creating workable rules will require serious, thoughtful study of all potential ramifications and a good understanding of what AI is now and where it is going, and (3) Rather than speak in generalities, the interplay between copyright and AI will need to be evaluated on their own facts and on a case-by-case basis.

January 24, 2022

Deferred Registration Examination Study

Summary:

The Copyright Alliance submitted comments to the U.S. Copyright Office in response to a Notice of Inquiry regarding its public study to evaluate the merits of providing an option to defer its examination of copyright registration application materials until examination is later requested.

January 5, 2022

Publishers’ Protections Study Additional Comments

Summary:

The Copyright Alliance filed additional comments in response to the notice and request for public comments by the U.S. Copyright Office regarding the Office’s public study evaluating current copyright protections for publishers. Reinforcing the importance of press publishers in our initial comments, the comments highlight that various considerations must be taken into account when evaluating the scope and applicability of copyright law to news content in the aggregation context. The comments also urge the Office to implement an effective registration system for dynamic web content.

December 15, 2021

Copyright Claims Board: Initiation of Proceedings and Related Procedures (Reply Comments)

Summary:

The Copyright Alliance (joined by 20 other organizations) submitted reply comments to the U.S. Copyright Office in response to a notice of proposed rulemaking regarding procedures governing the initial stages of a proceeding before the Copyright Claims Board.

November 30, 2021

Copyright Claims Board: Initiation of Proceedings and Related Procedures

Summary:

The Copyright Alliance (joined by 19 other organizations) submitted comments to the U.S. Copyright Office in response to a notice of proposed rulemaking regarding procedures governing the initial stages of a proceeding before the Copyright Claims Board.