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, 2023
Fees for Late Royalty Payments under the Music Modernization Act’s Blanket Mechanical License
U.S. Copyright Office
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 3, 2023
Study on Non-Fungible Tokens and Related Intellectual Property Law Issues
U.S. Copyright Office
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
U.S. Copyright Office
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)
U.S. Copyright Office
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.
October 17, 2022
Artificial Intelligence Export Competitiveness
International Trade Administration
Summary:
The Copyright Alliance submitted comments to the International Trade Administration (ITA) in response to the request for comments on Artificial Intelligence (AI) exports. The comments highlight the critical role the copyright community has on AI export competitiveness, identify trade barriers, challenges, and foreign and domestic policies that affect AI exports and copyright law, and urge the ITA to ensure that copyright law is respected and preserved in AI-related trade policies.
July 18, 2022
Best Edition Study
U.S. Copyright Office
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
U.S. Copyright Office
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
National Telecommunications and Information Administration
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
U.S. Copyright Office
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)
U.S. Copyright Office
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.