Exemptions to Permit Circumvention of Access Controls on Copyrighted Works
| Citation | 85 FR 37399 |
| Record Number | 2020-12911 |
| Published date | 22 June 2020 |
| Court | Copyright Office,Library Of Congress |
Federal Register, Volume 85 Issue 120 (Monday, June 22, 2020)
[Federal Register Volume 85, Number 120 (Monday, June 22, 2020)]
[Proposed Rules]
[Pages 37399-37403]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-12911]
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LIBRARY OF CONGRESS
Copyright Office
37 CFR Part 201
[Docket No. 2020-11]
Exemptions to Permit Circumvention of Access Controls on
Copyrighted Works
AGENCY: U.S. Copyright Office, Library of Congress.
ACTION: Notification of inquiry and request for petitions.
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SUMMARY: The United States Copyright Office is initiating the eighth
triennial rulemaking proceeding under the Digital Millennium Copyright
Act (``DMCA''), to consider possible temporary exemptions to the DMCA's
prohibition against circumvention of technological measures that
control access to copyrighted works. In this proceeding, the Copyright
Office is again providing a streamlined procedure for the renewal of
exemptions that were granted during the seventh triennial rulemaking.
If renewed, those current exemptions would remain in force for an
additional three-year period (October 2021-October 2024). Members of
the public seeking the renewal of current exemptions should submit
petitions as described below; parties opposing such renewal will then
have the opportunity to file comments in response. The Office is also
accepting petitions for new exemptions to engage in activities not
currently permitted by existing exemptions, which may include proposals
that expand upon a current exemption. Those petitions, and any renewal
petitions that are meaningfully opposed, will be considered pursuant to
a more comprehensive rulemaking process similar to that of the seventh
rulemaking, including three rounds of written comment, followed by
public hearings, which may be conducted virtually.
DATES: Written petitions for renewal of current exemptions must be
received no later than 11:59 p.m. Eastern Time on July 22, 2020.
Written comments in response to any petitions for renewal must be
received no later than 11:59 p.m. Eastern Time on September 8, 2020.
Written petitions for new exemptions must be received no later than
11:59 p.m. Eastern Time on September 8, 2020.
ADDRESSES: Written petitions for renewal of current exemptions must be
completed using the form provided on the Office's website at https://www.copyright.gov/1201/2021/renewal-petition.pdf. Written petitions
proposing new exemptions must be completed using the form provided on
the Office's website at https://www.copyright.gov/1201/2021/new-petition.pdf. The Copyright Office is using the regulations.gov system
for the submission and posting of public petitions and comments in this
proceeding. All petitions and comments are therefore to be submitted
electronically through regulations.gov. Specific instructions for
submitting petitions and comments are available on the Copyright Office
website at https://www.copyright.gov/1201/2021. If electronic
submission is not feasible, please contact the Office using the contact
information below for special instructions.
FOR FURTHER INFORMATION CONTACT: Regan A. Smith, General Counsel and
Associate Register of Copyrights, [email protected] or Kevin R.
Amer, Deputy General Counsel, [email protected]. They can be reached
by telephone at (202) 707-3000.
SUPPLEMENTARY INFORMATION:
I. The Digital Millennium Copyright Act and Section 1201
The Digital Millennium Copyright Act (``DMCA'') \1\ has played a
pivotal role in the development of the modern digital economy. Enacted
by Congress in 1998 to implement the United States' obligations under
two international treaties,\2\ the DMCA was intended to
[[Page 37400]]
foster the growth and development of a thriving, innovative, and
flexible digital marketplace by making digital networks safe places to
disseminate and use copyrighted materials.\3\ It did this by, among
other things, providing new legal protections for copyrighted content
made available in digital formats.\4\
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\1\ Public Law 105-304, 112 Stat. 2860 (1998).
\2\ WIPO Copyright Treaty, Dec. 20, 1996, 36 I.L.M. 65 (1997);
WIPO Performances and Phonograms Treaty, Dec. 20, 1996, 36 I.L.M. 76
(1997).
\3\ See Staff of H. Comm. on the Judiciary, 105th Cong.,
Section-by-Section Analysis of H.R. 2281 as Passed by the United
States House of Representatives on August 4th, 1998, at 2, 6 (Comm.
Print 1998) (``House Manager's Report''); H.R. Rep. No. 105-551, pt.
2, at 21, 23 (1998); H.R. Rep. No. 105-551, pt. 1, at 10 (1998); S.
Rep. No. 105-190, at 1-2, 8-9 (1998).
\4\ See House Manager's Report at 6 (noting Congress's intention
to ``support new ways of disseminating copyrighted materials to
users, and to safeguard the availability of legitimate uses of those
materials by individuals'').
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These protections, codified in section 1201 of title 17, United
States Code, seek to balance the interests of copyright owners and
users, including the personal interests of consumers, in the digital
environment.\5\ Section 1201 protects technological measures (also
called technological protection measures or TPMs) used by copyright
owners to prevent unauthorized access to or use of their works.\6\
Section 1201 contains three separate protections for TPMs. First, it
prohibits circumvention of technological measures employed by or on
behalf of copyright owners to protect access to their works (also known
as access controls). Access controls include, for example, a password
requirement limiting access to an online service to paying customers or
an authentication code in a video game console to prevent the playing
of pirated copies. Second, the statute prohibits trafficking in devices
or services primarily designed to circumvent access controls. Finally,
it prohibits trafficking in devices or services primarily designed to
circumvent TPMs used to protect the exclusive rights of the copyright
owner of a work (also known as copy controls). Copy controls protect
against unauthorized uses of a copyrighted work once access has been
lawfully obtained. They include, for example, technology preventing the
copying of an e-book after it has been downloaded to a user's device.
Because title 17 already provides remedies for copyright infringement,
there is no corresponding ban on the act of circumventing a copy
control.\7\ All these prohibitions supplement the preexisting rights of
copyright owners under the Copyright Act of 1976 by establishing
separate and distinct causes of action independent of any infringement
of copyright.\8\
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\5\ See H.R. Rep. No. 105-551, pt. 2, at 26.
\6\ 17 U.S.C. 1201(a)-(b).
\7\ S. Rep. No. 105-190, at 12.
\8\ See U.S. Copyright Office, Section 1201 of Title 17, at i,
iii, 43-45 (June 2017), https://www.copyright.gov/policy/1201/section-1201-full-report.pdf (``Section 1201 Study'').
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Section 1201 contains a number of specific exemptions to these
prohibitions, to avoid curtailing legitimate activities such as
security testing, law enforcement activities, or the protection of
personally identifying information.\9\ In addition, to accommodate
changing marketplace conditions and ensure that access to copyrighted
works for other lawful purposes is not unjustifiably diminished,\10\
the statute provides for a rulemaking proceeding where temporary
exemptions to the prohibition on circumventing access controls may be
adopted by the Librarian of Congress, upon the recommendation of the
Register of Copyrights in consultation with the Assistant Secretary for
Communications and Information of the Department of Commerce.\11\ In
contrast to the permanent exemptions set out by statute, exemptions
adopted pursuant to the rulemaking must be reconsidered every three
years.\12\ By statute, the triennial rulemaking process only addresses
the prohibition on circumvention of access controls; the statute does
not grant the authority to adopt exemptions to the anti-trafficking
provisions.\13\
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\9\ 17 U.S.C. 1201(d)-(j).
\10\ H.R. Rep. No. 105-551, pt. 2, at 35-36.
\11\ 17 U.S.C. 1201(a)(1)(C); see also id. 1201(a)(1)(B)-(D).
\12\ Id. 1201(a)(1)(C).
\13\ Id. 1201(a)(1)(C), (a)(1)(E).
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For an exemption to be granted through the triennial rulemaking, it
must be established that ``persons who are users of a copyrighted work
are, or are likely to be in the succeeding 3-year period, adversely
affected by the prohibition . . . in their ability to make
noninfringing uses under [title 17] of a particular class of
copyrighted works.'' \14\ In evaluating the evidence, several statutory
factors must be weighed: ``(i) the availability for use of copyrighted
works; (ii) the availability for use of works for nonprofit archival,
preservation, and educational purposes; (iii) the impact that the
prohibition on the circumvention of technological measures applied to
copyrighted works has on criticism, comment, news reporting, teaching,
scholarship, or research; (iv) the effect of circumvention of
technological measures on the market for or value of copyrighted works;
and (v) such other factors as the Librarian considers appropriate.''
\15\
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\14\ Id. 1201(a)(1)(C).
\15\ Id.
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II. Overview of the Rulemaking Process
To assess whether the implementation of access controls impairs the
ability of individuals to make noninfringing uses of copyrighted works,
the Copyright Office solicits exemption proposals from the public and
develops a comprehensive administrative record using information
submitted by interested parties.\16\ Based on that record, the Register
provides a written recommendation to the Librarian concerning which
exemptions are warranted based on that record. The recommendation
includes proposed regulatory text for adoption and publication in the
Federal Register.
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\16\ See H.R. Rep. No. 105-796, at 64 (1998) (Conf. Rep.) (``It
is the intention of the conferees that . . . the Register of
Copyrights will conduct the rulemaking, including providing notice
of the rulemaking, seeking comments from the public, consulting with
the Assistant Secretary for Communications and Information of the
Department of Commerce and any other agencies that are deemed
appropriate, and recommending final regulations in the report to the
Librarian.''); see also H.R. Rep. No. 106-464, at 149 (1999) (Conf.
Rep.) (``[T]he Copyright Office shall conduct the rulemaking under
section 1201(a)(1)(C) . . . .'').
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The rulemaking process for the eighth triennial proceeding will be
generally the same as the process followed in the seventh proceeding.
This includes the streamlined procedure introduced in the seventh
proceeding through which members of the public may petition for current
temporary exemptions that were granted during the previous rulemaking
to remain in force for an additional three-year period (October 2021-
October 2024).
With this notification of inquiry, the Copyright Office is
initiating the petition phase of the rulemaking, calling for the public
to submit petitions both to renew current exemptions, as well as any
comments in support of or opposition to such petitions, and to propose
new exemptions. This two-track petition process is described below.
After the close of the petition phase, the Office will publish a notice
of proposed rulemaking (``NPRM'') to initiate the next phase of the
rulemaking process, as described below.
Video tutorials explaining section 1201 in general and the
rulemaking process can be found on the Office's 1201 rulemaking web
page at https://www.copyright.gov/1201.
III. Process for Seeking Renewal of Current Exemptions
In the prior rulemaking, the Copyright Office introduced a
streamlined process
[[Page 37401]]
to facilitate the renewal of previously adopted exemptions for which
there was no meaningful opposition.\17\ This process was initiated
shortly after the Office concluded a comprehensive public policy study
of section 1201.\18\ In that study, following careful analysis of
relevant legal principles and noting a broad consensus of stakeholders
supporting an expedited process to consider renewal of such exemptions,
the Office concluded that ``the statute itself requires that exemptions
cannot be renewed automatically, presumptively, or otherwise, without a
fresh determination concerning the next three-year period. . . . [A]
determination must be made specifically for each triennial period.''
\19\ The Office further determined, however, that ``the statutory
language appears to be broad enough to permit determinations to be
based upon evidence drawn from prior proceedings, but only upon a
conclusion that this evidence remains reliable to support granting an
exemption in the current proceeding.'' \20\
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\17\ 82 FR 29804 (June 30, 2017).
\18\ See generally Section 1201 Study.
\19\ Id. at 142.
\20\ Id. at 143.
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Those seeking readoption of a current exemption may petition for
renewal by submitting the Copyright Office's required fillable form,
available on the Office's website at https://www.copyright.gov/1201/2021/renewal-petition.pdf. This form is for renewal petitions only. The
Office has a separate form, discussed below, for petitions for new
exemptions.
Scope of Renewal. Renewal may only be sought for current exemptions
as they are currently formulated, without modification. This means that
if a proponent seeks to engage in any activities not currently
permitted by an existing exemption, a petition for a new exemption must
be submitted. Where a petitioner seeks to engage in activities that
expand upon a current exemption, the Office recommends that the
petitioner submit both a petition to renew the current exemption, and,
separately, a petition for a new exemption. In such cases, the petition
for a new exemption need only discuss those issues relevant to the
proposed expansion of the current exemption. If the Office recommends
readoption of the current exemption, then only those discrete aspects
relevant to the expansion will be subject to the more comprehensive
rulemaking procedure described below.
Automatic Reconsideration. If the Office declines to recommend
renewal of a current exemption (as discussed below), the petition to
renew will automatically be treated as a petition for a new exemption,
and will be considered pursuant to the more comprehensive rulemaking
proceeding. If a proponent has petitioned both for renewal and an
expansion, and the Office declines to recommend renewal, the entire
exemption (i.e., the current exemption along with the proposed
expansion) will automatically be considered under the more
comprehensive proceeding.
Petition Form and Contents. The petition to renew is a short form
designed to let proponents identify themselves and the relevant
exemption, and to make certain sworn statements to the Copyright Office
concerning the existence of a continuing need and justification for the
exemption. Use of the Office's prepared form is mandatory, and
petitioners must follow the instructions contained in this notice and
on the petition form. A separate petition form must be submitted for
each current exemption for which renewal is sought. This is required
for reasons of administrability and so it is clear to which exemption
the stated basis for renewal applies. While a single petition may not
encompass more than one current exemption, the same party may submit
multiple petitions.
The petition form has four components:
1. Petitioner identity and contact information. The form asks for
each petitioner (i.e., the individual or entity seeking renewal) to
provide its name and the name of its representative, if any, along with
contact information. Any member of the public capable of making the
sworn declaration discussed below may submit a petition for renewal,
regardless of prior involvement with past rulemakings. Petitioners and/
or their representatives should be reachable through the provided
contact information for the duration of the rulemaking proceeding.
Multiple petitioning parties may jointly file a single petition.
2. Identification of the current exemption that is the subject of
the petition. The form lists all current exemptions granted during the
last rulemaking (codified at 37 CFR 201.40), with a check box next to
each. The exemption for which renewal is sought is to be identified by
marking the appropriate checkbox.
3. Explanation of need for renewal. The petitioner must provide a
brief explanation summarizing the basis for claiming a continuing need
and justification for the exemption. The required showing is meant to
be minimal. The Office anticipates that petitioners will provide a
paragraph or two detailing this information, but there is no page
limit. While it is permissible to attach supporting documentary
evidence as exhibits to the petition, it is not necessary. The Office's
petition form includes an example of what it regards as a sufficient
explanation.
4. Declaration and signature. One of the petitioners named in the
petition must sign a declaration attesting to the continued need for
the exemption and the truth of the explanation provided in support.
Where the petitioner is an entity, the declaration must be signed by an
individual at the organization having appropriate personal knowledge to
make the declaration. The declaration may be signed electronically.
For the attestation to be trustworthy and reliable, it is important
that the petitioner make it based on his or her own personal knowledge
and experience. This requirement should not be burdensome, as a broad
range of individuals have a sufficient level of knowledge and
experience. For example, a blind individual having difficulty finding
and purchasing e-books with appropriate assistive technologies would
have such personal knowledge and experience to make the declaration
with regard to the assistive technology exemption; so would a relevant
employee or volunteer at an organization like the American Foundation
for the Blind, which advocates for the blind, visually impaired, and
print disabled, is familiar with the needs of the community, and is
well-versed specifically in the e-book accessibility issue. It would be
improper, however, for a general member of the public to petition for
renewal if he or she knows nothing more about matters concerning e-book
accessibility other than what he or she might have read in a brief
newspaper article, or simply opposes the use of digital rights
management tools as a matter of general principle.
The declaration also requires affirmation that, to the best of the
petitioner's knowledge, there has not been any material change in the
facts, law, or other circumstances set forth in the prior rulemaking
record (available at https://www.copyright.gov/1201/2018) that
originally demonstrated the need for the selected exemption, such that
renewal of the exemption would not be justified. By ``material
change,'' the Office means a significant change in the underlying
conditions that originally justified the exemption when it was first
granted, such that the appropriateness of continuing the exemption for
another three years based on that original
[[Page 37402]]
justification is called into question. This attestation tells the
Office that the prior rulemaking record from when the current exemption
was originally granted is still ripe and applicable in considering
whether or not the same exemption is appropriate for the subsequent
triennial period. Only after finding the old record to still be germane
can the Office rely upon it in deciding, pursuant to 17 U.S.C.
1201(a)(1)(C), whether to recommend renewal.
C. Comments in Response to a Petition To Renew an Exemption
Any interested party may respond to a petition to renew a current
exemption by submitting comments. While the primary purpose of these
comments is to allow for opposition to renewing the exemption, comments
in support of renewal are also permitted. Although no form is being
provided for such comments, the first page of any responsive comments
must clearly identify which exemption's readoption is being supported
or opposed. While participants may comment on more than one exemption,
a single submission may not address more than one exemption. For
example, a party that wishes to oppose the renewal of both the wireless
device unlocking exemption and the jailbreaking exemption must file
separate comments for each.\21\ The Office acknowledges that this
format may require some parties to repeat certain general information
(e.g., about their organization) across multiple submissions, but the
Office believes that the administrative benefits of creating self-
contained, separate records for each exemption will be worth the modest
amount of added effort involved.
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\21\ Commenters may, however, respond to multiple petitions to
renew the same exemption in a single submission. For instance, if
the Office receives six petitions in favor of readopting the current
wireless device unlocking exemption, a commenter can file a single
comment that addresses points made in the six petitions. That
comment, however, may not address petitions to readopt the
jailbreaking exemption.
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Opposition to a renewal petition must be meaningful, such that,
from the evidence provided, it would be reasonable for the Office to
conclude that the prior rulemaking record and any further information
provided in the renewal petition are insufficient to support
recommending renewal of an exemption. For example, a change in case law
might affect whether a particular use is noninfringing, new
technological developments might affect the availability for use of
copyrighted works, or new business models might affect the market for
or value of copyrighted works. Such evidence could cause the Office to
conclude that the prior evidentiary record is too stale to rely upon
for an assessment affecting the subsequent three-year period. The
Office may also consider whether opposition is meaningful only as to
part of a current exemption.
Unsupported conclusory opinion and speculation will not be enough
for the Office to refuse to recommend renewing an exemption it would
have otherwise recommended in the absence of any opposition, or to
subject consideration of this exemption to the more comprehensive
rulemaking procedure.
IV. Process for Seeking New Exemptions
Those seeking to engage in activities not currently permitted by an
existing exemption, including activities that expand upon a current
exemption, may propose a new exemption by filing a petition using the
Copyright Office's required fillable form, available on the Office's
website at https://www.copyright.gov/1201/2021/new-petition.pdf. Use of
the Office's prepared form is mandatory, and petitioners must follow
the instructions contained in this notice and on the petition form. As
in the seventh rulemaking, a separate petition must be filed for each
proposed exemption. The Office anticipates that it will, once again,
receive a significant number of submissions, and requiring separate
submissions for each proposed exemption will help both participants and
the Office keep better track of the record for each proposed exemption.
Although a single petition may not encompass more than one proposed
exemption, the same party may submit multiple petitions.
The petition form has two components:
1. Petitioner identity and contact information. The form asks for
each petitioner (i.e., the individual or entity proposing the
exemption) to provide its name and the name of its representative, if
any, along with contact information. Petitioners and/or their
representatives should be reachable through the provided contact
information for the duration of the rulemaking proceeding. Multiple
petitioning parties may jointly file a single petition.
2. Description of the proposed exemption. At this stage, the Office
is only asking petitioners to briefly explain the nature of the
proposed new or expanded exemption. The information that would be most
helpful to the Office includes the following, to the extent relevant:
(1) The types of copyrighted works that need to be accessed; (2) the
physical media or devices on which the works are stored or the services
through which the works are accessed; (3) the purposes for which the
works need to be accessed; (4) the types of users who want access; and
(5) the barriers that currently exist or which are likely to exist in
the near future preventing these users from obtaining access to the
relevant copyrighted works.
To be clear, petitioners do not need to propose precise regulatory
language or fully define the contours of an exemption class in the
petition. A short, plain statement describing the nature of the
activities the petitioners wish to engage in is sufficient. Although
there is no page limit, the Office anticipates that petitioners will be
able to adequately describe in plain terms the relevant information in
a few sentences. The Office's petition form includes examples of what
it regards as a sufficient description of a requested exemption.
Nor does the Office intend for petitioners to deliver the complete
legal and evidentiary basis for their proposals in the petition, and
specifically requests that petitioners not do so. Rather, the sole
purpose of the petition is to provide the Office with basic information
about the uses of copyrighted works that are adversely affected by the
prohibition on circumvention. The Office will then use that information
to itself formulate categories of potential exemptions, and group
similar proposals into those categories, for purposes of the next, more
substantive, phase of the rulemaking beginning with the publication of
the NPRM.
Indeed, as during the previous two rulemakings, even the NPRM will
not ``put forward precise regulatory language for the proposed classes,
because any specific language for exemptions that the Register
ultimately recommends to the Librarian will necessarily depend on the
full record developed during this rulemaking.'' \22\ Rather, the
proposed categories of exemptions described in the NPRM will
``represent only a starting point for further consideration in the
rulemaking proceeding, and will be subject to further refinement based
on the record.'' \23\ Thus, proponents will have the opportunity to
further refine or expound upon their initial petitions during later
phases of the rulemaking.
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\22\ 82 FR at 29807 (quoting 79 FR 73856, 73859 (Dec. 12,
2014)).
\23\ Id. (internal quotation marks and citation omitted).
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V. Notice of Proposed Rulemaking
Following receipt of all petitions, as well as comments on
petitions for
[[Page 37403]]
renewal, the Office will evaluate the material received and will issue
an NPRM addressing all of the potential exemptions to be considered in
the rulemaking.
The NPRM will set forth which exemptions the Register will
recommend for readoption, along with proposed regulatory language. The
NPRM will also identify any exemptions the Register has declined to
recommend for renewal under the streamlined process, after considering
any opposition received. Those exemptions will instead be subject to
the more comprehensive rulemaking procedure in order to build out the
administrative record. The Register will not at the NPRM stage make a
final determination to reject recommendation of any exemption that
meets the threshold requirements of section 1201(a).\24\
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\24\ See 79 FR 55687, 55692 (Sept. 17, 2014) (explaining that
part of the purpose of providing the information in the petition
phase is so the Office can ``confirm that the threshold requirements
of section 1201(a) can be met''); see also 79 FR at 73859 (noting
that three petitions sought an exemption which could not be granted
as a matter of law and declining to put them forward for comment).
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For current exemptions for which renewal was sought but which were
not recommended for readoption through the streamlined process and all
new exemptions, including proposals to expand current exemptions, the
NPRM will group them appropriately, describe them, and initiate at
least three rounds of public comment. As with the seventh rulemaking,
the Office plans to consolidate or group related and/or overlapping
proposed exemptions where possible to simplify the rulemaking process
and encourage joint participation among parties with common interests
(though such collaboration is not required). As in previous
rulemakings, the exemptions as described in the NPRM will represent
only a starting point for further consideration in the rulemaking
proceeding, and will be subject to further refinement based on the
record. The NPRM will provide guidance regarding specific areas of
legal and factual interest for the Office with respect to each proposed
exemption, and suggest particular types of evidence that participants
may wish to submit for the record. It will also contain additional
instructions and requirements for submitting comments and will detail
the later phases of the rulemaking proceeding--i.e., public hearings,
post-hearing questions, recommendation, and final rule--which will be
similar to those of the seventh rulemaking.
The Office expects to follow a similar timeframe for issuance of
the NPRM and submission of comments that applied during the seventh
rulemaking. In addition, as it did in the previous rulemaking, the
Office will look for opportunities to discuss discrete issues,
including suggestions regarding regulatory language, through its ex
parte meeting process, and to ask additional post-hearing questions,
where necessary to ensure sufficient stakeholder participation.\25\
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\25\ See 82 FR at 29808; U.S. Copyright Office, Ex Parte
Communications, https://www.copyright.gov/1201/2018/ex-parte-communications.html; U.S. Copyright Office, Additional
Correspondence from Participants in Proposed Class 10, https://www.copyright.gov/1201/2018/additional-correspondence/; Section 1201
Study at 150-51.
Dated: June 11, 2020.
Regan A. Smith,
General Counsel and Associate Register of Copyrights.
[FR Doc. 2020-12911 Filed 6-19-20; 8:45 am]
BILLING CODE 1410-30-P
