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).

February 6, 2026

Working Paper on Generative AI and Copyright: Part 1

Summary:

On February 6, the Copyright Alliance submitted comments to the Department of Promotion of Industry and Internal Trade of India in response to the Working Paper on Generative AI and Copyright: Part 1. The comments highlight the growth of the voluntary AI licensing market for use of copyrighted works for AI training purposes and urge the Indian Government to reject its proposal for a compulsory licensing scheme to instead embrace and promote voluntary AI licensing supported by strong copyright laws.

January 14, 2026

Request for Information; Partnerships for Transformational Artificial Intelligence Models

Summary:

The Copyright Alliance submitted comments in response to the request for information (RFI) published by the Department of Energy (DOE) in the Federal Register on December 5, 2025, requesting input on “how DOE should best structure and enable partnerships to curate DOE scientific data across the National Laboratory complex for use in artificial intelligence (AI) models” and on “using this data to develop self-improving AI models for science and engineering to advance scientific discovery, energy, and national security.” The comments urge that any new policies aimed at structuring and enabling partnerships to curate DOE scientific data for use in AI models (i) be developed and implemented with a respect for and in recognition of longstanding copyright laws and policies that make America the global leader in scientific discovery and technological progress, and (ii) do not disrupt the critical scientific and research publishing industries, the incentives upon which they are based, or the licensing markets that sustain them.

December 23, 2025

Request for Information; Accelerating the American Scientific Enterprise

Summary:

The Copyright Alliance submitted comments in response to the request for information (RFI) published by the Office of Science and Technology Policy (OSTP) in the Federal Register on November 26, 2025, requesting input from stakeholders regarding priorities for strengthening the science and technology (S&T) ecosystem to support both the expansion of scientific knowledge and the mechanisms to transition these discoveries into the marketplace. The comments explain that copyright incentivizes private investment, enables sustainable business models for research dissemination, protects the interests of human creators and innovators, and ensures that the benefits of scientific progress are broadly shared while maintaining the economic incentives necessary for continued innovation. Thus, any policies should acknowledge existing copyright laws, respect and support the flourishing free market for licensing, and require transparency for AI developers.

October 27, 2025

Request for Information; Regulatory Reform on Artificial Intelligence

Summary:

The Copyright Alliance submitted comments in response to the request for information (RFI) published by the Office of Science and Technology Policy (OSTP) in the Federal Register on September 26, 2025, requesting input to identify existing Federal statutes, regulations, agency rules, guidance, forms, and administrative processes that unnecessarily hinder the development, deployment, and adoption of artificial intelligence (AI) technologies within the United States. The comments explain that copyright should not be viewed as a barrier to AI development, but rather the underlying foundation that ensures trustworthy and beneficial generative AI development. The comments recommend that any policies adopted by the Administration: (i) are developed and implemented with a respect for and recognition of longstanding copyright laws and policies that make America the global leader in the creative and digital industries and in AI, and (ii) do not hinder the development, deployment, and adoption of generative AI technologies within the United States by disrupting the existing and growing copyright licensing market for AI-related uses.

September 12, 2025

Harnessing Data and Digital Technology

Summary:

The Copyright Alliance filed comments responding to Productivity Commission (“PC”) of the Australian Government, in response to the Inquiry on the Harnessing Data and Digital Technology: Interim Report. The Copyright Alliance raised objections to a proposal made by the PC to introduce a text-and-data mining (“TDM”) exception to expand the country’s fair dealing provision, urging the PC and Australian Government to not adopt the proposal. The comments also highlight the robust AI and copyright licensing market to illustrate that copyright is vital for AI development.

June 23, 2025

CASE Act Study (Reply Comments)

Summary:

The Copyright Alliance filed reply comments responding to initial comments submitted to the Copyright Office’s notice of inquiry on issues pertaining to the Copyright Claims Board (CCB). The reply comments urge the Office to reject suggestions which restrict the accessibility of the CCB and create barriers for CCB claimants or counterclaimants contesting counternotices filed under Section 512(g)(2)(C). The reply comments also reiterate the importance of persistent and continued educational efforts to inform the public about CCB proceedings.

June 23, 2025

Thailand Draft AI Principles

Summary:

On June 23, the Copyright Alliance filed comments in response to a consultation on draft AI principles launched by Thailand’s Ministry of Digital Economy and Society (DES) through its Electronic Transactions Development Agency (ETDA). The Copyright Alliance’s comments raised objections to the Thailand Government’s proposal to introduce text-and-data mining (TDM) exceptions similar to the exceptions in the European Union and highlighted the virtues of licensing and the existence of the AI licensing market for copyrighted works.

May 9, 2025

CASE Act Study (Initial Comments)

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

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

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.