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).

July 18, 2022

Best Edition Study

Summary:

The Copyright Alliance submitted comments to the U.S. Copyright Office in response to the Notice of Inquiry (NOI) regarding the Office’s public study on copyright deposit and best edition requirements. The comments suggest that the Office reduce the burdens of the current “best edition” deposit requirements on copyright owners, the Library of Congress, and the Copyright Office by allowing the Library articulate which types of copyrighted works they would like best edition copies and by permitting/expanding the options of submission of electronic copies.

May 27, 2022

Standard Technical Measures and Section 512

Summary:

The Copyright Alliance submitted comments to the U.S. Copyright Office in response to a notice of inquiry on the development and use of standard technical measures for the protection and identification of copyrighted works. The Copyright Alliance answered several questions touching on existing standard technical measures, obstacles to adoption of existing technologies, and interpretations of and improvements to various parts of section 512(i)(2)(A) of the Copyright Act.

May 23, 2022

Developing a Report on Competition in the Mobile App Ecosystem

Summary:

The Copyright Alliance submitted comments to the National Telecommunications and Information Administration (NTIA) in response to a request for comments (RFC) regarding developing a report on competition in the mobile app ecosystem. The Copyright Alliance asks that NTIA examine the harms of infringement on the legitimate mobile app ecosystem and consider setting forth guidelines and best practices for screening app developers and their apps to combat fraudulent and infringing apps.

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.