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).

November 26, 2021

Publishers’ Protections Study

Summary:

On November 26, the Copyright Alliance submitted comments to the U.S. Copyright Office in response to a notice and request for public comments regarding the Office’s public study which will evaluate current copyright protections for publishers.

October 4, 2021

Small Claims Procedures for Library and Archives Opt-Outs and Class Actions

Summary:

On October 4, 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 for library and archives opt-outs and class actions under the CASE Act.

May 26, 2021

Copyright Alternative in Small-Claims Enforcement (‘‘CASE’’) Act Regulations: Expedited Registration and FOIA

Summary:

On May 26, the Copyright Alliance (joined by 20 other organizations) submitted comments to the U.S. Copyright Office in response to a notice of proposed rulemaking regarding the Expedited Registration and FOIA provisions of the Copyright Alternative in Small Claims Enforcement (“CASE”) Act.

May 10, 2021

Copyright Alternative in Small-Claims Enforcement (‘‘CASE’’) Act Regulations (Reply Comments)

Summary:

On May 10, the Copyright Alliance, along with 18 other organizations, submitted reply comments to the U.S. Copyright Office in response to a notice of inquiry regarding implementation of the Copyright Alternative in Small Claims Enforcement (“CASE”) Act.

April 26, 2021

Copyright Alternative in Small-Claims Enforcement (‘‘CASE’’) Act Regulations (Initial Comments)

Summary:

On April 26, the Copyright Alliance along with 18 other organizations submitted comments to the U.S. Copyright Office in response to a notice of inquiry regarding implementation of the Copyright Alternative in Small Claims Enforcement (“CASE”) Act.

March 12, 2021

Development of a National Consumer Awareness Campaign on Combating the Trafficking in Counterfeit and Pirated Products

Summary:

The Copyright Alliance submitted comments to the U.S. Patent and Trademark Office (USPTO) in response to its Notice of Inquiry (NOI) seeking information from stakeholders on the “Development of a National Consumer Awareness Campaign on Combatting the Trafficking in Counterfeit and Pirated Goods” as a public-private partnership. The comments provide information on the many ways the Copyright Alliance educates stakeholders on the value of copyright and the risks associated with copyright infringement, and they offer support for the establishment of coordinated campaigns and partnerships led by federal, state and local governments under the guidance of the USPTO and U.S. Copyright Office that would ensure all consumers are aware of the dangers and harms associated with copyright infringement and other forms of intellectual property theft. 

February 23, 2021

National Strategy for Expanding American Innovation

Summary:

The Copyright Alliance and the Institute of IP and Social Justice submitted comments in response to the U.S. Patent and Trademark Office’s (USPTO) notice soliciting input “from the public that will be used to help draft a national strategy to create opportunities that will expand our innovation ecosystem to include all individuals, including those from underrepresented socioeconomic, geographic, and demographic groups.” While none of the questions in the notice reference copyright explicitly, these comments underscore the importance of diversity and inclusion across all forms of IP, including copyright.

October 22, 2020

Sovereign Immunity Study Reply Comments

Summary:

The Copyright Alliance filed reply comments in response to a Notice of Inquiry (NOI) by the U.S. Copyright Office initiating a public study on the degree to which copyright owners are experiencing infringement by state entities without adequate remedies under state law. Highlighting data presented in our initial comments, the comments also refute arguments made by organizations that submitted comments in opposition of abrogating sovereign immunity. The reply comments conclude that the previous round of comments provided sufficient evidence to support the abrogation of state sovereign immunity and that the comments opposed to abrogation are neither persuasive nor supported by sufficient evidence.

September 2, 2020

Sovereign Immunity Study

Summary:

In response to a Notice of Inquiry (NOI) by the U.S. Copyright Office initiating a public study on the degree to which copyright owners are experiencing infringement by state entities without adequate remedies under state law, the Copyright Alliance launched a public survey and conducted interviews with a number of individual creators and organizations that have encountered state infringement. The comments demonstrate compelling evidence that remedies against state infringement are inadequate, and urge that the Copyright Office recommend, and that Congress enact, legislation that abrogates state sovereign immunity pursuant to Section 5 of the Fourteenth Amendment.

August 5, 2020

Modernizing Recordation of Notices of Termination

Summary:

The Copyright Alliance submitted comments in response to the Notice of Proposed Rulemaking and Notification of Inquiry published by the U.S. Copyright Office regarding proposed amendments to regulations governing the recordation of notices of termination, and related practice updates.