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).
May 9, 2025
CASE Act Study (Initial Comments)
U.S. Copyright Office
Summary:
The Copyright Alliance filed comments in response to the Copyright Office’s notice of inquiry on issues pertaining to the Copyright Claims Board (CCB), including its use and efficacy. The comments commend the Copyright Office for its tremendous work on launching the CCB and for the work done to ensure the CCB’s successful operations and educational outreach. The comments suggest some improvements to the CCB process and urge the Copyright Office and the CCB to conduct further educational outreach to increase awareness of the CCB.
April 11, 2025
Issues Related to Performing Rights Organizations
U.S. Copyright Office
Summary:
On April 11, the Copyright Alliance submitted comments to the U.S. Copyright Office in response to a notice of inquiry regarding issues related to performance rights organizations (“PROs”) and the Copyright Act’s public performance right for musical works. The Copyright Alliance’s comments highlight the critical role of PROs in the public performance licensing space for musical works and note that no changes in copyright law are needed to address issues raised in the NOI.
March 14, 2025
Request for Information on the Development of an Artificial Intelligence (AI) Action Plan
Office of Science and Technology Policy
Summary:
The Copyright Alliance submitted comments in response to the request for information (RFI) published by the Networking and Information Technology Research and Development (NITRD) National Coordination Office (NCO), National Science Foundation on behalf of the Office of Science and Technology Policy (OSTP) in the Federal Register on February 6, 2025, requesting input from interested parties on priority actions that should be included in the Administration’s Artificial Intelligence (AI) Action Plan. The comments urge that the AI Action Plan be developed with a respect for and recognition of longstanding copyright laws and policies that make America the global leader in the creative and digital industries. They also warn that no policy should be adopted that interferes with the free market and the freedom of copyright owners and generative AI companies and developers to enter into licensing agreements.
February 25, 2025
Consultation on Copyright and Artificial Intelligence
UK IPO
Summary:
The Copyright Alliance submitted comments in response to the Consultation on Copyright and Artificial Intelligence launched by the United Kingdom Intellectual Property Office (UK IPO). The comments urge the UK Government to reject a proposal for a text-and-data mining exception in UK copyright law, highlight the inadequacies of various “safeguards” in the proposal, and emphasize the need for adequate transparency and recordkeeping measures.
September 6, 2024
Public Consultation on Copyright and Artificial Intelligence (2024)
CEDB and IPD of Hong Kong
Summary:
On September 6, the Copyright Alliance submitted comments in response to the Commerce and Economic Development Bureau (CEDB) and Intellectual Property Department (IPD) of Hong Kong in response to the Public Consultation on Copyright and Artificial Intelligence (2024) (“Consultation”), specifically concerning Chapter 4 of the Consultation and the proposal for a tailored exception for text and data mining (“Proposed TDM Exception”). The comments highlight that the Proposed TDM Exception undermines the fundamental rights of creators and copyright owners, potentially violates international IP obligations, and runs counter to other countries’ approaches to AI, including the United States.
May 17, 2024
2024 Public Consultation on Prescribed Exceptions
IPOS and MinLaw of Singapore
Summary:
On May 17, the Copyright Alliance and the European Publishers Council (EPC) jointly submitted comments in response to the 2024 Public Consultation on Prescribed Exceptions in Part 6, Division 1 of the Copyright Regulations 2021 launched by the Intellectual Property Office of Singapore (IPOS) and the Ministry of Law of Singapore (MinLaw). The comments raised several concerns with the proposal in Annex B to permit the circumvention of technological protection measures for the use of copyright-protected works and protected performances for computational data analysis.
April 1, 2024
Group Registration of Two-Dimensional Artworks
U.S. Copyright Office
Summary:
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.
February 20, 2024
Group Registration of Updates to a News Website
U.S. Copyright Office
Summary:
On February 20, the Copyright Alliance submitted comments in response to the U.S. Copyright Office’s notice of proposed rulemaking (NPRM) regarding the creation of a new group registration option for frequently updated news websites. The comments applauded the Copyright Office for enacting the rule, suggested changes to enable greater flexibility for news media publishers to register news content, and urged the Office to update its discussion on statutory damages to acknowledge the independent economic value test.
February 2, 2024
Petition for Right-to-Repair Rulemaking
Federal Trade Commission
Summary:
The Copyright Alliance submitted comments in response to a request for comments published by the Federal Trade Commission (FTC) on January 3, 2024, regarding the Commission’s receipt of a petition from the U.S. Public Interest Research Group Education Fund (PIRG) and iFixit requesting the Commission “initiate a rulemaking to protect consumers’ right to repair products they have purchased.” The comments highlight the successful application of section 1201 and the triennial rulemaking process and caution against any agency actions that would disrupt copyright law or override the authority of the Copyright Office.
December 6, 2023
Artificial Intelligence and Copyright (Reply Comments)
U.S. Copyright Office
Summary:
The Copyright Alliance submitted reply comments in response to the Copyright Office’s notice of inquiry and request for comments on Artificial Intelligence and Copyright. The comments respond to many arguments made in the initial comment period, including those that claim case law supports a categorical fair use exception for generative AI training and that AI ingestion only involves the copying of non-protectable elements. The reply comments also stress that licensing for AI ingestion is possible, different AI models raise unique issues that require specific analysis, and AI companies are not immune from secondary liability under “Sony Safe Harbor.”