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).

August 23, 2023

Future Strategies in Anticounterfeiting and Antipiracy

Summary:

The Copyright Alliance submitted comments in response to the U.S. Patent and Trademark Office’s (USPTO) request for public comments on Future Strategies in Anticounterfeiting and Antipiracy. The comments address a range of copyright piracy issues, including the need for better education for consumers, the ineffectiveness of certain provisions of the DMCA, and the need for the adoption of site-blocking mechanisms in the U.S.

August 11, 2023

Advancing Inclusive, Worker-Created Trade Policy

Summary:

The Copyright Alliance and the Institute for Intellectual Property and Social Justice (IIPSJ) filed comments in response to the request for comments (RFC) published by the Office of the U.S. Trade Representative (USTR) in the Federal Register on June 12, 2023, regarding how trade and investment policy may be designed to expand the benefits of trade to include underserved and marginalized communities here in the United States and with trading partners who share concerns about rising inequality.

July 7, 2023

Request for Information; National Priorities for Artificial Intelligence

Summary:

The Copyright Alliance filed comments in response to the request for information (RFI) published by the Office of Science and Technology Policy (OSTP) in the Federal Register on May 26, 2023, requesting comments to help OSTP update U.S. national priorities and future actions on artificial intelligence (AI). The comments focus on issues related to protecting the rights of creators and copyright owners and promoting economic growth.

June 20, 2023

Copyright Claims Board Agreement-Based Counterclaims

Summary:

The Copyright Alliance submitted comments to the U.S. Copyright Office’s request for comments its proposed regulations for agreement-based counterclaims filed with the Copyright Claims Board (CCB). While the comments do not raise substantive objections with the rule, they reiterate the importance of ensuring that CCB rules and regulations do not become cumbersome or complex for pro se parties and that regulations governing protective orders should continue to be applicable.

June 12, 2023

AI Accountability Policy Request for Comment

Summary:

The Copyright Alliance filed comments in response to the request for comments published by the National Telecommunications and Information Administration (NTIA) in the Federal Register on April 13, 2023, regarding self-regulatory, regulatory, and other measures and policies that are designed to provide assurance that artificial intelligence (AI) systems are legal, effective, ethical, safe, and otherwise trustworthy. The comments discuss accountability and transparency in the context of ingestion of copyrighted works by AI systems.

May 9, 2023

Fees for Late Royalty Payments under the Music Modernization Act’s Blanket Mechanical License

Summary:

The Copyright Alliance submitted reply comments in response to the notice of inquiry published by the U.S. Copyright Office in the Federal Register on February 23, 2023, regarding when fees for late royalty payments should be assessed in connection with reporting by digital music providers under the Music Modernization Act’s blanket license.

February 17, 2023

Comments on the USPTO’s Draft 2022-2026 Strategic Plan

Summary:

The Copyright Alliance submitted comments in response to a request for public comments on the U.S. Patent and Trademark Office’s (USPTO) Draft 2022-2026 Strategic Plan. The comments supports the Office’s proposed objectives on combatting piracy and identifies tools and other areas of interest that the USPTO’s guidance and initiative would continue the agency’s commitment to protecting U.S. creators and innovators.

February 3, 2023

Study on Non-Fungible Tokens and Related Intellectual Property Law Issues

Summary:

The Copyright Alliance submitted comments to the U.S. Copyright Office in response to the Notice of Inquiry (NOI) regarding the Office’s joint study with the U.S. Patent and Trademark Office on the intellectual property issues related to non-fungible tokens (NFTs). The comments discuss the many opportunities and challenges copyright owners and creators have encountered in the NFT space. The comments also explain that, at this time, NFTs do not pose any particularly unique issues that would require a change in copyright law.

February 2, 2023

Copyright Claims Board: District Court Referrals; Proof of Service Forms; Default Proceedings; Law Student Representation

Summary:

The Copyright Alliance submitted comments to the U.S. Copyright Office in response to a request for comments published by the U.S. Copyright Office in the Federal Register on December 19, 2022, regarding the interim rule amending Copyright Claims Board (CCB) regulations governing the appearance of law student representatives, district court referrals, proof of service forms, and default proceedings.

November 17, 2022

Copyright Claims Board: Active Proceedings and Evidence (Smaller Claims)

Summary:

The Copyright Alliance submitted comments to the U.S. Copyright Office in response to a request for comments regarding the Copyright Claims Board (CCB) procedures for “smaller claims” codified at 37 CFR Part 226.