Copyright Office
The House Judiciary Committee has sent a letter to the Register of Copyrights, Shira Perlmutter, requesting an examination of “concerns” and “emerging issues” related to performing rights organizations (PROs).
In the letter, signed by the committee’s chairmen Rep. Jim Jordan and Rep. Darrell Issa as well as member Rep. Scott Fitzgerald, two particular areas of concern are addressed: the “proliferation” of new PROs and the lack of transparency about the distribution of general licensing revenue.
The letter, obtained by Billboard, notes the latter issue is of particular importance to independent artists and smaller publishers. “It is difficult to assess how efficiently PROs are distributing general licensing revenue based on publicly available data,” the letter reads. “For example, it is difficult to determine how accurately lesser known and independent artists as well as smaller publishers are being compensated compared to widely popular artists and major publishers.”
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Concerns around transparency at the PROs are not new. The National Music Publishers’ Association, the trade organization representing music publishers, has spoken publicly about it, as have a number of individual songwriters and publishers over the years. These concerns grew last year after BMI, one of the largest PROs in the country, switched its business model from non-profit to for-profit and was acquired by private equity firm New Mountain Capital.
At the end of BMI’s fiscal year 2022, Billboard reported that “for the first time ever, it hardly contains any financial information.”
“I believe that you have a fundamental right to know what it costs you to use a particular collection society now I will tell you that ASCAP gives you a pretty close look at what it costs not exactly, but they give you a pretty close ballpark,” said NMPA CEO and president David Israelite at an Association of Independent Music Publishers’ Meeting in February. “BMI at the end of the last fiscal year we didn’t get that information.”
The letter states that it “request[s] that the Office examine how the various PROs currently gather information from live music venues, music services, and other general licensees about public performance; the level of information currently provided by PROs to the public; whether any gaps or discrepancies occur in royalty distribution; what technological and business practices exist or could be developed to improve the current system; the extent to which the current distribution practices are the result of existing legal and regulatory constraints; and potential recommendations for policymakers.”
The “proliferation” of PROs is a newer concern. Around the world, most countries typically have one PRO for local writers and publishers to join. In the U.S., it works differently. For over a hundred years, ASCAP and BMI have been the primary choices for a songwriter or publisher looking to collect performance royalties in the United States, but there is also the option to go with SESAC instead, a smaller but still important player in the U.S. PRO landscape, which has been around for almost as long.
Since its founding in 2013, Global Music Rights (GMR), a for-profit PRO founded by industry veteran Irving Azoff, has become a heavyweight in the space as well. GMR business model is to focus on a smaller roster of only the top tier of songwriters and then charging a premium to the bars, venues, shops and theaters that wanted to play them. Because their roster includes major artists including Bruce Springsteen, Billie Eilish, Drake, and more, the GMR blanket license became immediately important for licensees to have, no matter the cost.
In 2017, a fifth U.S.-based PRO emerged. AllTrack was founded by media investor and former SESAC-board member Hayden Bower and is designed to focus on indie creators with a tech-forward approach. This year, AllTrack became the fourth U.S. PRO to be accepted by the International Confederation of Socities of Authors and Composers (CISAC), along with ASCAP, BMI and SESAC.
“Licensees [like bars, restaurants and small businesses] have reported receiving demands for royalties from new entities claiming to represent songwriters… Licensees are concerned that the proliferation of PROs represents an ever-present danger of infringement allegations and potential litigation risk from new and unknown sources,” the letter states.
“We request that the USCO examine the increased costs and burdens imposed on licensees for paying an ever-increasing number of PROs, factors that may be contributing to the proliferation of new PROs, and recommendations on how to improve clarity and certainty for licensees,” it continues.
Perlmutter and the Copyright Office cannot make any specific changes to the way PROs work today, but often letters like this are sent in hopes that it will draw attention to particular issues or become the predicate for a hearing or draft bill.
The U.S. Copyright Office has finalized a new rule aimed at ensuring that songwriters who invoke termination rights to regain control of their music will actually start getting paid streaming royalties after they do so.
The provision, issued on Tuesday, will overturn what the Copyright Office called an “erroneous” earlier policy by the Mechanical Licensing Collective, which critics feared would have kept sending money from streamers like Spotify to former owners in perpetuity, long after a songwriter took back ownership.
Proposals to force the MLC to change that approach, first reported by Billboard in 2022, were supported by a slew of songwriters like Don Henley, Sheryl Crow and Sting, who feared they would be “deprived of the rights afforded to them by copyright law.” The effort was led by groups including the Music Artists Coalition, Songwriters of North America, Black Music Action Coalition and the Recording Academy.
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In a statement on Tuesday, Music Artists Coalition board member Jordan Bromley called the Copyright Office’s new termination rule a “landmark victory for songwriters.”
“This decision not only ensures fair compensation for songwriters who reclaim their rights, but also sets a precedent that strengthens the very foundation of copyright law in the digital age,” Bromley said. “It’s a clear message that in the evolving landscape of music streaming and licensing, the rights of creators must be protected and respected.”
A spokeswoman for the MLC did not return a request for comment.
HOW IT WORKS
The new rule issued Tuesday addresses complex questions about how MLC’s blanket license for streaming royalties, created by the Music Modernization Act in 2018, interacts with so-called termination rights – a federal provision that empowers authors to reclaim the rights to their copyrighted works decades after selling them away.
Though a powerful tool for songwriters, termination comes with an important exception. Even though a publisher must hand back the rights to the original song, they’re entitled to keep selling any existing “derivative works” they created when they owned it. Those continue to be fair game, and any fees under existing licenses keep flowing back to their old publisher.
That exception makes practical sense: It would be unfair to let a terminating songwriter suddenly send cease-and-desists over a famous sample that had been legal when it was initially cleared, or sue over a movie that featured the song under a synch license. But it also creates difficult ambiguity for the MLC and the blanket license.
Say a songwriter terminates their publisher’s control of their music. The writer is now the owner of those songs — that’s easy to figure out. But by paying the MLC for access to the blanket license, Spotify arguably already has an existing license in place with the old publisher. So, isn’t the copy of the song on Spotify an existing derivative work? And shouldn’t the royalties from it continue to go to the old publisher under that license?
Under a dispute resolution policy issued by MLC in 2021, that appeared to be the case. The rules seemed to choose who to pay based on when a song was uploaded to a digital streamer’s servers; if it was uploaded prior to when a songwriter invoked their termination right, the royalties would keep going to the old owner — seemingly forever.
The MLC’s approach was not intended as a scheme to hurt songwriters. According to the Copyright Office, the group saw it as a “middle ground,” aimed at preventing drawn-out disputes that would lock up royalty payments “to the disadvantage of both songwriters and publishers.” But advocates argued that it would undermine the very purpose of termination rights, which were created to level the playing field for small creators who sold their works away to powerful companies.
In October 2022, the Copyright Office largely agreed. In a proposed new rule, the agency said the MLC’s policy was based on an “erroneous understanding and application of current law.” Ordering the group to “immediately repeal its policy in full,” the proposal said that when a songwriter gets their rights back, they should obviously start getting the royalties, too.
Nearly two years later, that rule was finalized on Tuesday. The final version retains most of the core features of the original proposal, though certain elements have been changed to address “practical and administrative concerns” raised by industry groups. In particular, the agency said it had modified how the rule identifies the payee to whom the MLC must distribute royalties, and pushed back deadlines to give the MLC more time to “update its processes and systems.”
QUIETING THE CRITICS
Over the past two years, the proposed rule underwent a so-called public comment period, during which it was met with both support and criticism from outside groups. According to Tuesday’s final rule, one of the “principal critics” was the National Music Publisher’s Association, which argued that the MLC’s original approach had been supported by historical precedent in industry practice.
In the new rule, the Copyright Office said it was “not persuaded by NMPA’s argument” on that issue.
“We do not dispute NMPA’s assertion that certain publishers may have adopted a different approach to termination, but this approach is not supported by the law in the context of the blanket license,” the agency wrote. “The Office is not adopting a new position, or changing the law as it relates to termination or the exception. Nor are we contending that the MMA or blanket license altered the law as it relates to the exception. The Office is merely stating what the law is and has always been.”
The Copyright Office also rejected separate arguments from the NMPA that the new rule was an impermissible “retroactive” rule, or even an unconstitutional “taking” that violated the Fifth Amendment. In doing so, the agency said that “these royalties always belonged to the post-termination copyright owner” and that the new rule simply “implements the law as it already existed.”
Despite earlier disagreements, NMPA President & CEO David Israelite celebrated the final enactment of the rule in a statement Tuesday, saying the group was pleased with a policy that “ensures songwriters are properly and expediently paid post termination.”
“Having clear guidance on this issue will make the MLC and larger industry even more efficient as it gives a clear roadmap to those who have decided to reclaim their copyrights,” Israelite said. “The songwriter groups deserve much credit for working with the Copyright Office and music publishers to push for this decision.”
A spokesperson for the NMPA declined to comment the Copyright Office’s decisions on the group’s specific objections.
Notably, the new rule will not just change the MLC’s approach going forward, but also require “corrective royalty adjustments” to address any money that was paid improperly under the old policy. But such payments are likely to be relatively small: In filings, the MLC has said that it voluntarily suspended the old termination policy while the case played out at the Copyright Office, and that it expects any corrections to total “less than $2 million.”
You can read the entire new rule here.
The United States Copyright Office is giving the Mechanical Licensing Collective (MLC) and the Digital Licensee Coordinator (DLC) five-year check-ups with a re-designation process to ensure both are effectively fulfilling their purposes. Though this is the first time the organizations have been through this process, it is a routine occurrence that will take place every five years.
Under the review, both organizations must show compliance with the Music Modernization Act, which was passed in 2018 to replace the old song-by-song licensing system for digital streaming services with a new blanket license for musical work mechanicals. To administer the new blanket license, the MMA called for a mechanical licensing collective to be established.
At that time two entities applied, and the MLC was chosen because it was the only one that fit the MMA’s “endorsement” criteria, which said that the organization chosen as MLC had to have the support of much of the publishers and songwriters affected by the blanket license. The endorsement was meant to be “based on market share” and “measured by applicable licensing revenue.” Among others, the MLC was notably supported by the National Music Publishers Association (NMPA), which represents the major publishers and many of the sizable indie publishers, giving it a robust coalition of support.
Similarly, the Digital Licensee Collector was intended to represent the majority interests of digital music providers affected by the blanket license in matters related to its administration. The DLC was the sole applicant and was supported by the major music streamers and the Digital Media Association (DiMA) trade organization. Both the MLC and DLC assumed their roles in 2019.
The review process will begin with the MLC and DLC writing self-reports about their performances to date as well as developments they are planning in the future.
In their comments, the two organizations will need to address several key points, as mandated by the Copyright Office. Among them: whether they have ample endorsements for their different sectors, whether they have the administrative capabilities necessary to fulfill their roles, how they govern themselves and more. The MLC must also respond to whether it has made progress on implementing the Copyright Office’s suggestions in their ‘Unclaimed Royalties’ report, and the DLC must explain how it has participated in the Copyright Royalty Board.
This self-reporting will be made available for the public. Songwriters, publishers and digital music providers can also submit their feedback about whether or not the MLC and the DLC should continue as they have been. The MLC and the DLC will then be allowed to respond to public submissions. There could also be “informal” meetings between the copyright office and the organizations to address “discrete issues” prior to making the final re-designation determination.
Last June, Congress gave the MMA a five-year review — inviting a number of stakeholders, including the leaders of DiMA and the MLC — to speak to the strengths and weaknesses of the MMA and the MLC. The comments submitted in this proceeding will likely echo some of what was raised at this hearing.
If the MLC or DLC are rejected, the Copyright Office will ask for proposals for new offices that could handle these roles in the Federal Register. But it is not expected for either organization to be replaced.
“We welcome the announcement of the Register of Copyrights commencing the first review of The MLC’s designation as required by the MMA,” says MLC CEO Kris Ahrend about the re-designation. “We are confident that this review will confirm that The MLC continues to meet all of the criteria set out in the MMA, while affording us the opportunity to highlight the many successes our team and our stakeholders have achieved since launching The MLC’s full operations.”
The U.S. Copyright Office issued a ruling on Tuesday (Sept. 5), confirming that songwriters and publishers are owed late fees when streaming services do not pay royalties to the Mechanical Licensing Collective (The MLC) on time. This, however, does not apply to the major adjustments in royalty payments currently underway following the re-setting of Phonorecords III rates (2018-2022), according to the office.
Late fees have been an ongoing debate between the music publishing industry and streaming services dating back to the passage of the Music Modernization Act (the MMA) in 2018. That landmark law switched how streaming services licensed music, from a song-by-song piecemeal system — which many considered ineffective and cumbersome — to a blanket licensing regime instead.
The law took effect starting Jan. 1, 2021, requiring digital music providers like Spotify and Apple Music to go to the newly created MLC to obtain a blanket mechanical license to reproduce music on these platforms. As part of the new system, streamers had to pay out royalties owed to the MLC, which then pays the writers and publishers, each month. More specifically, the law stipulates mechanicals are due “45 calendar days after the end of the monthly reporting period.”
After that, any lagging payment is considered late and subject to additional penalties, according to the MMA. For the current period of Phonorecords IV (2023-2027), the Copyright Royalty Board judges say that a streaming service must pay a late fee of 1.5% per month, or the highest lawful rate, whichever of those two is lower, for any payment owed to the music’s copyright owners that hadn’t been paid on time. The late fees accrue from the due date until the copyright owner receives payment.
The main source of debate around late fees is whether they should apply in the case of a monthly payment that needs adjustment after it is paid out. Streaming services have argued that “‘[i]f a service is following the regulations by making a reasonable estimate of an input it does not know the value of, it should not be penalized with a late fee even if it so happens that the estimate is too low.”
On the other side, the MLC has argued that allowing such exceptions would incentivize the streaming services to intentionally draw up payment estimates that undervalue what is owed to songwriters and publishers.
The Tuesday ruling by the Copyright Office settles the debate: “The Office concludes that the statute’s due date provisions are unambiguous. The statute’s reference to ‘due date for payment’ clearly refers to the date on which monthly royalty payments are required to be delivered to the MLC, i.e., no later than forty-five days after the end of the monthly reporting period.”
“This is a major victory for music creators who have waited far too long to be made whole from the appeal which significantly delayed their compensation,” says NMPA President and CEO David Israelite. “The USCO’s decision reiterates our assertion that the due dates are unambiguous and any past-due payments to the MLC must come with appropriate statutory penalties.”
Music “as we know it” has been prematurely pronounced dead several times over. The cassette tape, MIDI digital synthesizers, Napster, Auto-Tune and streaming were all received with apocalyptic hysteria. The current existential threat is artificial intelligence (AI), a software leviathan with a voracious appetite for copyrighted works, and a prolific capacity for human-free creative processes. Whether AI will kill the humanity of music remains debatable. What is not up for debate is that AI raises many legal issues. While courts have yet to weigh in, the U.S. Copyright Office has issued instructive decisions and made AI-related copyright issues a 2023 priority.
The proliferation of AI in music
AI in music is not new. Alan Turing, the godfather of computer science, created a simple melody-making machine in 1951. Experimental trombonist and composer George Lewis improvised a live quartet with three Apple II computers in 1984. David Bowie experimented with a digital lyric randomizer in the 90s. Hello, World, the first AI composed pop album, was released in 2018.
Today’s AI is more evolved and exponentially more impactful. Indirect enhancements (personalized playlists, music recommendations, etc.) have given way to direct creation tools. For example, Google’s Magenta wrote a new “Nirvana” song by analyzing the melody, chord changes, guitar riffs and lyrics of the band’s past works. ChatGPT receives text instructions to compose lyrics superior to those that IBM Watson wrote for Alex da Kid in 2016. Authentic Artists leases AI-powered artists-for-hire. MUSICinYOU.ai generates tailored compositions from a 300-question personality test. Bandlab’s Songstarter is an “AI-powered idea generator” capable of creating royalty-free music in seconds. Startup Staccato pitches itself as “an AI Lennon to your McCartney” given its ability to bounce ideas off human songwriters.
Only “sufficient human creative input” supports copyright ownership
The Copyright Act protects “works of authorship” – a concept derived from the U.S. Constitution’s Copyright Clause, which empowers Congress to secure “exclusive rights” for “authors.” Courts have held that authors must be human. Consequently, animals (including the famed monkey selfie) and natural forces (a naturally growing garden) cannot be authors of copyrighted works.
While current legal precedent suggests that AI also cannot “author” copyrighted works, the critical issue is what amount of human creative input or intervention suffices to make AI-generated musical works copyrightable (and by whom)?
U.S. courts have yet to answer this question decisively. The Copyright Office has drawn some basic boundary lines. AI-advocate Steven Thaler filed a copyright application for AI-generated artwork. The Board rejected his applications three times, finding that the artwork was not “created with contribution from a human author” and thus failed to meet the human authorship requirement. (Thaler has since sued.)
Conversely, copyright protection was afforded to David Cope’s 1997 work Classical Music Composed by Computer (and, again, to his 2010 album From Darkness, Light). Cope successfully demonstrated that his works only partially used AI and were the result of sufficient human creative input and intervention. More recently, the Copyright Office granted a first-of-its-kind copyright to a comic book created with the assistance of text-to-image AI Midjourney (though the Copyright Office is now reconsidering its decision).
In the absence of bright line rules for ascertaining how much input or intervention by an AI’s user is needed, each work must be individually evaluated. It is a question of degree. Under traditional principles, the more human involvement, and the more AI is used as a tool (and not as the creator), the stronger the case for copyright protection. A song created with the prompt: “create a song that sounds like The Weeknd” will not suffice. But a copyright application which both: (i) demonstrates that a human controlled the AI and (ii) memorializes the specific human input in the creative process is more likely to succeed.
A word of caution: the Copyright Office has made clear that misrepresenting the use of AI in the music generation process is fraudulent. And although the Copyright Office solely relies on facts stated in applications, both it and future litigants are likely to soon deploy AI-detecting software to verify the extent to which AI was used to generate the musical work.
AI “training” looms as the first major battle ground
Generative AI software (like Magenta) is “trained” by feeding it vast quantities of content – text, lyrics, code, audio, written compositions – and then programming it to use that source material to generate new material. In October 2022, the RIAA shot a warning flare by declaring that AI-based extractors and mixers were infringing its members’ rights by using their music to train their AI models. Those that side with the RIAA argue that AI’s mindboggling ingestion of copyrighted music violates the Copyright Act’s exclusive rights to reproduce and create “derivative works” based upon one or more preexisting works. Because generative AI produces output “based upon” preexisting works (input), copyright owners insist that a license is needed.
On the other hand, AI-advocates argue that the use of such data for training falls within copyright law’s “fair use” exception, claiming that the resulting work is transformative, does not create substantially similar works, and has no material impact on the original work’s market. They contend that the training data has been sufficiently transformed by the AI process to yield musical works beyond the copyright protection of the original works.
These competing views are likely to be tested in the class action lawsuit just filed on behalf of a group of artists against Stability AI, DeviantArt, and Midjourney for allegedly infringing “billions of copyrighted images” in creating AI art. (Getty Images recently filed a comparable lawsuit against Stability AI in the U.K.).
Proving infringement with AI-works
How exactly the AI was trained and operates will be issues in copyright infringement litigations. Proving infringement is a two-step process. The plaintiff must demonstrate that copying occurred; and that the copying is unlawful, because the defendant copied too much of the plaintiff’s protected expression and is, therefore, substantially similar.
The first of these inquiries can be proven by direct evidence of copying or circumstantially by establishing access to a specific, allegedly infringed musical work. With art, there is a Spawning AI software called “Have I Been Trained” which allows users to search through the images used to train AI art generators. While no known current analog exists for music, the technology is likely imminent.
The nature of the AI instructions will also be crucial to showing an awareness of the original work and substantial similarity between the AI-generated music and the allegedly infringed music. Prompts that intentionally draw on copyrighted works (i.e., create a work in “the style of _”) undoubtedly bear on the issue of substantial similarity. The marketplace is pivoting in advance of anticipated rulings: Songmastr has, for example, stopped marketing its ability to create songs based on the styles of Beyonce and Taylor Swift.
AI is evolving faster than the courts can evaluate how laws apply to it. The just-filed art litigation may provide some clarity; however, while in the fog, those creating AI-generated music are well-advised to stay cognizant of the legal risks and guide the artificial music making process with a genuine human touch.
James Sammataro is a partner and Nicholas Saady an associate at Pryor Cashman LLP.
Don Henley, Sheryl Crow, Sting and a slew of other musicians are throwing their support behind a new federal copyright rule aimed at making sure that songwriters who regain control of their music actually start getting paid their streaming royalties after they do so.
As first reported by Billboard in October, the U.S. Copyright Office wants to overturn a policy adopted by the Mechanical Licensing Collective (which collects streaming royalties) that critics fear might lead to a bizarre outcome: Even after a writer uses their so-called termination right to take back control of their songs, royalties may continue to flow in perpetuity to the old publishers that no longer own them.
In a letter Thursday organized by the Music Artists Coalition, more than 350 artists, songwriters, managers and music lawyers urged the Copyright Office to grant final approval for the proposed rule, warning that “music creators must not be deprived of the rights afforded to them by copyright law.”
“We stand together in support of USCO’s rule and believe that anything contrary would undermine the clear Congressional intent to allow songwriters, after an extended period of time, to reap the benefit of the songs they create,” the signatories wrote to the Copyright Office.
“It is simple, a songwriter who validly terminates a prior grant is the correct recipient of royalties,” the group wrote. “A publisher whose grant was terminated – and has received the benefit of the songwriter’s work for decades – is not the proper or intended recipient of these royalties.”
To fully understand the legal complexities of the Copyright Office’s proposed rule and what it might mean for songwriters, read this explainer.
Thursday’s letter, also signed by Bob Seger, Maren Morris, John Mayer, Dave Matthews, members of the Black Keys and others, came on the final day of the so-called “comment period,” in which outside groups could submit their opinion on the Copyright Office’s proposed rule.
The letter was the product of a call for signatures by the Irving Azoff-led Music Artists Coalition, which, along with other groups like Songwriters of North America, the Black Music Action Coalition and the Nashville Songwriters Association International, helped raise the alarm about the issue and spurred the Copyright Office to take action last year.
“Too often, music artists are quietly stripped of their rights,” Azoff said in a statement to Billboard announcing the letter. “But, today, the industry stood up to say ‘Not on our watch!’ We applaud the Copyright Office for its proposed rule. This rule should pass unamended and without delay.”
The Copyright Office introduced its new rule in October, saying the MLC’s policy had been based on an “erroneous” understanding of the law that created ambiguity about who should be receiving streaming royalties after a songwriter invokes their termination right and regains ownership of their music. Ordering MLC to “immediately repeal its policy in full,” the new proposal would make clear that when a songwriter takes back their music, they should obviously start getting the royalties, too.
In a message to members ahead of Thursday’s letter, MAC offered a plain-English explainer of the complex legal mechanics at play in the situation. The group urged its members to help end what it believed amounted to a loophole in the system created by 2018’s Music Modernization Act, warning that it could defeat the very purpose of both the new law and termination.
In an interview with Billboard, Susan Genco, co-president of The Azoff Company and a leader at MAC, said the group’s call to action – and the letter that came from it — was an example of how songwriters have become better mobilized after years of being “kept in the dark” on complicated policy matters that could have adverse effects.
“This is a big part of our role, to figure out which issues impact music creators the most, prioritize them, and then explain them to the community,” Genco said.
“We tried to paint a very clear picture for them,” added Jordan Bromley, a prominent music attorney and another key member of MAC, in the same interview. “Oh you think you’re getting your streaming mechanicals back through termination? Think again.”
In addition to advocating for the new rule, Thursday’s letter also came with something of a warning. The final sentence, separated into its own paragraph, read: “Any view opposing the USCO’s rule is a vote against songwriters.”
While not outright oppositional, the Copyright Office has received pushback on the proposed changes from the National Music Publishers’ Association. In a Dec. 1 submission, the group said it supported the overall goal of the new rule, but warned that the agency’s proposed approach “may have far-reaching and unintended consequences” and would likely lead to litigation in other spheres. Among other issues, the group said the rule must not apply retroactively.
“The breadth of the USCO’s legal reasoning in the [proposed rule] seems likely to increase legal uncertainty and questions,” the NMPA wrote. “This uncertainty will almost definitely raise the likelihood of litigation … including litigation concerning past payments made in accordance with what was then industry custom and practice.”
The NMPA instead advocated for “a consensus-based legislative solution” that would be passed by Congress, which it said could be narrower and more “carefully crafted” to avoid the problems the group has with the Copyright Office’s legal analysis.
In a statement to Billboard, NMPA president David Israelite stressed the industry group was aligned with songwriters on the ultimate policy goal.
“We strongly support songwriters receiving all mechanical royalties after a termination and have been working towards crafting legislation to ensure that outcome for years alongside the major songwriter groups,” Israelite said. “While not a concrete legislative remedy, our comments reflect our support for the Copyright Office’s proposed rule and offer ways to make that rule even more robust and less susceptible to legal challenges.”
The text of the Copyright Office’s proposed rule is available in its entirety on the agency’s website. The public comment period ended on Thursday, but all submitted comments will be made public on a public docket. The agency will review all comments and issue a final rule in the months ahead.
Read the entire letter sent to the Copyright Office on Thursday here:
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