Registration Modernization

Published date03 March 2020
Record Number2020-04435
SectionProposed rules
CourtCopyright Office
Federal Register, Volume 85 Issue 42 (Tuesday, March 3, 2020)
[Federal Register Volume 85, Number 42 (Tuesday, March 3, 2020)]
                [Proposed Rules]
                [Pages 12704-12714]
                From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
                [FR Doc No: 2020-04435]
                [[Page 12703]]
                Vol. 85
                Tuesday,
                No. 42
                March 3, 2020
                Part IIILibrary of Congress-----------------------------------------------------------------------Copyright Office-----------------------------------------------------------------------37 CFR Parts 201 and 202Registration Modernization; Proposed Rule
                Federal Register / Vol. 85, No. 42 / Tuesday, March 3, 2020 /
                Proposed Rules
                [[Page 12704]]
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                LIBRARY OF CONGRESS
                 Copyright Office
                37 CFR Parts 201 and 202
                [Docket No. 2018-9]
                Registration Modernization
                AGENCY: U.S. Copyright Office, Library of Congress.
                ACTION: Statement of policy and notification of inquiry.
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                SUMMARY: In conjunction with the development of new technological
                infrastructure for the copyright registration system, on October 17,
                2018, the U.S. Copyright Office solicited public input regarding
                potential regulatory and practice updates to improve the system's
                efficiency for both users and the Office. The Office sought and
                received public comment on three main areas of proposed reform: The
                administration and substance of the application for registration, the
                utility of the public record, and the deposit requirements for
                registration. After reviewing the comments, the Office is announcing
                intended practice updates, to be adopted in conjunction with the
                deployment of the new technological system that the Library of Congress
                is building for the Office. The Office also seeks further comment on
                two proposals to permit post-registration edits to rights and
                permissions information, and to permit voluntary submission of
                additional deposit information to be included in the public record.
                DATES: Written comments must be received no later than 11:59 p.m.
                Eastern Time on April 2, 2020.
                ADDRESSES: For reasons of government efficiency, the Copyright Office
                is using the regulations.gov system for the submission and posting of
                public comments in this proceeding. All comments are therefore to be
                submitted electronically through regulations.gov. Specific instructions
                for submitting comments are available on the Copyright Office website
                at https://www.copyright.gov/rulemaking/reg-modernization/. If
                electronic submission of comments is not feasible due to lack of access
                to a computer and/or the internet, 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]; Robert J.
                Kasunic, Associate Register of Copyrights and Director of Registration
                Policy and Practice, [email protected]; Kevin Amer, Deputy General
                Counsel, [email protected]; Erik Bertin, Deputy Director of
                Registration Policy and Practice, [email protected]; or Jalyce E.
                Mangum, Attorney-Advisor, [email protected]. They can be reached by
                telephone at 202-707-3000.
                SUPPLEMENTARY INFORMATION: A highly functional registration system is
                of paramount importance to the Copyright Office as it administers title
                17 for the benefit of the nation's thriving copyright ecosystem.\1\
                Copyright registration provides valuable benefits to copyright owners,
                including providing access to federal court to initiate a lawsuit for
                infringement of a U.S. work,\2\ serving as prima facie evidence of the
                validity of the copyright and the facts stated in the certificate of
                registration,\3\ and enabling copyright owners to seek statutory
                damages and attorneys' fees in litigation for works that are timely
                registered.\4\ Registration also benefits users and prospective users
                of creative works by enabling them to find key facts relating to the
                authorship and ownership of such works in the Office's online public
                record.\5\
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                 \1\ See 17 U.S.C. 701(a) (``All administrative functions and
                duties under this title . . . are the responsibility of the Register
                of Copyrights as director of the Copyright Office of the Library of
                Congress.'').
                 \2\ 17 U.S.C. 411(a).
                 \3\ 17 U.S.C. 410(c).
                 \4\ 17 U.S.C. 412.
                 \5\ Additional information is available at https://www.copyright.gov/registration/.
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                 Accordingly, modernizing the technological infrastructure of the
                copyright registration system is one of the Office's top priorities.
                The Office is working with the Library of Congress's Office of Chief
                Information Officer (``OCIO''), which is building an enterprise
                copyright system (``ECS'') to improve the Office's provision of
                copyright services to the public, including its registration services.
                Copyright Office information technology (IT) modernization is being
                implemented in accordance with the overall model of IT centralization
                at the Library of Congress. Under this model, ``the Copyright Office,
                with its expertise of both copyright law and its internal systems,
                provides required business features to the OCIO. The OCIO then uses its
                expertise to develop technology solutions to support those features for
                the Copyright Office.'' \6\
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                 \6\ Library of Congress Modernization Oversight: Hearing Before
                the S. Comm. on Rules and Admin., 116th Cong. 24 (2019) (Statement
                of Carla Hayden, Librarian of Congress).
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                 To take advantage of forthcoming IT modernization development
                efforts and promote an efficient and innovative registration system,
                the Office published a notice of inquiry in October 2018 (``2018 NOI'')
                inviting public comment on several potential practice and policy
                changes to better meet the demands of users of the registration system
                in the digital age.\7\ The 2018 NOI previewed technological features
                that the Office would like to be incorporated into the ECS, including a
                more dynamic application tracking dashboard, an integrated drag-and-
                drop submission option for electronic deposits, and an improved
                messaging system to improve communication between the Office and
                applicants.\8\ The Office also announced an intention to display a
                draft version of the registration certificate before final submission
                so that applicants can confirm that they have entered the correct
                information.\9\ In addition to announcing these intended user features,
                the Office posed fifteen questions that fell into three categories of
                possible reform: (1) The administration and substance of the
                application for registration, (2) the utility of the public record, and
                (3) the deposit requirements for registration.\10\
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                 \7\ Registration Modernization, 83 FR 52336 (Oct. 17, 2018).
                 \8\ Id. at 52337.
                 \9\ Id. A similar display feature will be provided in the
                forthcoming electronic recordation system pilot.
                 \10\ Id.
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                 Commenters expressed broad general support for the proposals set
                forth in the 2018 NOI. The Copyright Alliance was ``pleased that the
                Office is considering a broad range of legal and policy changes
                regarding registration, and seeking input from stakeholders early in
                that process.'' \11\ Noting that ``[a] modernized registration system
                is key for the healthy functioning of the copyright ecosystem in the
                21st century,'' the Association of American Publishers (``AAP'')
                expressed support for many of the Office's ``innovative proposals to
                make the registration process more efficient, intuitive, and
                competitive,'' \12\ and the American Intellectual Property Law
                Association (``AIPLA'') specifically praised the proposed updates that
                would allow ``user-errors [to] be reduced through
                [[Page 12705]]
                self-correction and proofing prior to filing.'' \13\
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                 \11\ Copyright Alliance Comments, at 1-2 (Jan. 15, 2019); see
                also, e.g., National Music Publishers' Association (``NMPA'')
                Comments, at 3 (Jan. 15, 2019) (``NMPA appreciates the opportunity
                to comment on how the Office can design a registration system that
                will fit the needs of the modern music industry.''); Recording
                Industry Association of America, Inc. (``RIAA'') Comments, at 2
                (Jan. 15, 2019) (``RIAA and its members applaud the Copyright Office
                . . . for thinking broadly about a variety of steps that could be
                taken to modernize the current copyright registration process.'').
                Unless otherwise noted, all comments cited refer to comments
                submitted in response to the 2018 Notice of Inquiry Regarding
                Registration Modernization.
                 \12\ AAP Comments, at 8 (Jan. 15, 2019).
                 \13\ AIPLA Comments, at 2 (Jan. 15, 2019).
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                 Other commenters opined that the Office's proposals did not address
                all of the shortcomings of the current registration system. For
                example, the Coalition of Visual Artists (``CVA'') cautioned the Office
                to avoid making incremental improvements when a comprehensive
                modernization effort is necessary to make the registration system
                easier and more cost effective for authors to use.\14\ The Graphic
                Artists Guild (``GAG'') similarly contended that the modernization
                effort should not ``proceed in a piecemeal fashion, without substantive
                changes to a system that for individual visual artists is broken.''
                \15\ It expressed particular concern about registration processing
                times, highlighting that ``[t]he processing time for the simplest
                online copyright registrations, requiring no communication, averages
                six months.'' \16\
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                 \14\ CVA Comments, at 2-3 (Jan. 15, 2019).
                 \15\ GAG Comments, at 2 (Jan. 15, 2019).
                 \16\ Id. at 1.
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                 The Office takes these comments seriously and is pleased to note
                that, separate from the IT modernization process, it already has taken
                significant steps toward addressing a number of commenters' concerns.
                For example, the Office has made extensive efforts to reduce
                registration processing times, particularly in light of the Supreme
                Court's 2019 decision in Fourth Estate Public Benefit Corp. v. Wall-Street.com, which confirmed that Copyright Office action on an
                application for registration must be complete before the owner of a
                U.S. work can bring an infringement suit.\17\ Since 2018, the average
                processing time for claims that are received through the electronic
                registration system and do not require correspondence (which make up
                seventy-two percent of claims) has been reduced from six months to
                three months.\18\
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                 \17\ 139 S. Ct. 881, 888, 892 (2019).
                 \18\ U.S. Copyright Office, Registration Processing Times,
                https://www.copyright.gov/registration/docs/processing-times-faqs.pdf. The data is from April 1 through September 30, 2019.
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                 As a second example apart from IT modernization, the Office has
                also issued a notice of inquiry requesting written comments on issues
                relating to online publication, including whether and how to amend its
                registration regulations and other considerations relevant to ensuring
                continued thorough assistance to Congress.\19\ This notice seeks to
                address recent feedback to the Office suggesting that the statutorily-
                drawn distinction between published and unpublished works is, as
                Copyright Alliance put it, ``so complex and divergent from an intuitive
                and colloquial understanding of the terms that it serves as a barrier
                to registration, especially with respect to works that are disseminated
                online.'' \20\ The Office will analyze these issues related to online
                publication, as well as other potential practice changes,
                contemporaneously with, yet separately from, the OCIO's efforts to
                upgrade the IT system through establishment of an ECS. While the
                Copyright Office remains dedicated to continuously exploring potential
                regulatory and/or practice changes through public discussion, the
                current Registration Modernization proceeding focuses on the practices
                directly relevant to the pending technological upgrades. The Library
                has committed to an IT development approach that can meet ``the complex
                and unique mission of the Copyright Office today and for the future,''
                including ``to accommodate possible future legal responsibilities'' and
                to meet ``evolving business needs.'' \21\ To the extent the publication
                proceeding, other pending or future rulemakings, result in regulatory
                or practice changes that need to be accommodated in the Office's
                technology, the Office will communicate those requirements to the OCIO,
                but such changes will be considered separately from the umbrella of
                ``modernization.'' \22\
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                 \19\ See Online Publication, 84 FR 66328 (Dec. 4, 2019).
                 \20\ 84 FR at 66328 (citing Copyright Alliance Comments, at 5
                (Jan. 15, 2019)).
                 \21\ Letter from Carla Hayden, Librarian of Congress, and Karyn
                A. Temple, Register of Copyrights & Dir., to Hon. Thom Tillis,
                United States Senate, 2-3 (Sept. 30, 2019), https://www.copyright.gov/rulemaking/reg-modernization/letter-to-senator-thom-tillis.pdf.
                 \22\ As one exception; separately, the Office has issued two
                interim rules connected to the related IT modernization efforts with
                respect to its Recordation program. See Modernizing Copyright
                Recordation, 82 FR 52213 (Nov. 13, 2017); 85 FR 3854 (Jan. 23,
                2020).
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                 With respect to IT modernization, the Office is prioritizing public
                outreach to gain additional information about the needs and concerns of
                users of the registration system. The Office created a dedicated IT
                modernization web page to keep stakeholders apprised of the status of
                modernization efforts.\23\ In early 2019, the Office launched a
                bimonthly webinar series to report on the progress achieved on IT
                modernization initiatives and to discuss the overall direction of
                modernization.\24\ And the Office continues to meet regularly with
                stakeholders and deliver presentations to external audiences to provide
                updates on modernization activities. OCIO user experience (UX) experts
                are also committed and involved to ensure that development can
                incorporate public input through robust user participation and
                feedback.\25\
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                 \23\ U.S. Copyright Office, Copyright Modernization, https://www.copyright.gov/copyright-modernization/.
                 \24\ U.S. Copyright Office, Modernization Webinar, https://www.copyright.gov/copyright-modernization/webinar/.
                 \25\ Letter from Carla Hayden, Librarian of Congress, and Karyn
                A. Temple, Register of Copyrights & Dir., to Hon. Thom Tillis,
                United States Senate, 4-5 (Sept. 30, 2019), https://www.copyright.gov/rulemaking/reg-modernization/letter-to-senator-thom-tillis.pdf; Letter from Carla Hayden, Librarian of Congress, to
                Thom Tillis, Chairman, S. Comm. on the Judiciary, Subcomm. on
                Intellectual Prop., and Christopher A. Coons, Ranking Member, S.
                Comm. on the Judiciary, Subcomm. on Intellectual Prop., 8-9 (Jan. 7,
                2020), https://www.judiciary.senate.gov/imo/media/doc/Hayden%20Responses%20to%20QFRs.pdf.
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                 To further advance these efforts, and following careful
                consideration of the comments received in response to the 2018 NOI, the
                Office is now announcing plans to adopt eleven registration practice
                updates that it will identify as business needs to the OCIO, so that
                they may be incorporated into the design of the new ECS to support a
                more user-friendly and efficient registration process that is simpler,
                clearer, secure, and adaptable. As detailed below, these updates relate
                to both the substance of the registration application and the utility
                of the online public record from a registration-specific perspective.
                The Office has concluded that each of these intended practice changes
                or design features can be incorporated into the ECS without adjusting
                existing regulatory language. As development efforts progress, the
                Office envisions initiating a pilot program that could permit
                incorporation of these updates through an iterative process that also
                takes into account participants' input, similar to the recently-
                announced pilot for the electronic recordation system.\26\
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                 \26\ See 85 FR at 3854.
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                 The Office also seeks further input from the public regarding two
                additional issues: (1) How the Office might implement a system that
                would allow users to make post-registration amendments to rights and
                permissions and unique identifier information; and (2) further
                considerations related to the possibility of permitting the voluntary
                submission of an additional public-facing deposit, that may display
                low-resolution or incomplete portions of the registered work to enhance
                the public record.
                [[Page 12706]]
                I. Registration Practice Updates
                (A) The Application Process: How Users Engage With the Registration
                System
                (1) New Application Assistance Tools
                 Recognizing that users approach the system with varying levels of
                understanding of copyright law and technical experience, the NOI sought
                input on how the Office should integrate in-application support and
                assistance to users of the electronic registration system. The Office
                proposed multi-tiered support options to offer basic, intermediate, or
                in-depth support based on user experience level.\27\
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                 \27\ 83 FR at 52338.
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                 All commenters expressed support for some form of improved
                assistance for users.\28\ Some encouraged the Office to focus on
                improving the materials and resources currently available to
                applicants, with, for example, the AAP and the Motion Picture
                Association of America, Inc. (``MPAA'') urging the Office to expand
                upon its existing Frequently Asked Questions web page.\29\ The
                Association of Medical Illustrators (``AMI'') proposed that the Office
                provide a service similar to that of the U.S. Patent and Trademark
                Office (``USPTO''), which ``maintains an inventor assistance hotline as
                well as a call center providing live, telephonic assistance in
                resolving problems of formalities of electronically submitted patent
                applications.'' \30\
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                 \28\ See AIPLA Comments, at 2 (``AIPLA . . . supports including
                more embedded links to provide immediate help in completing each
                section of the online application.''); Copyright Alliance Comments,
                at 4 (``As an organization that represents a diverse group of
                copyright owners--including individual creators, and small and large
                businesses--the Copyright Alliance supports a multi-tier approach to
                in-application support and assistance that would more effectively
                meet the specific needs of both novice and experienced
                applicants.''); NMPA Comments, at 3 (``NMPA supports a multi-tiered
                approach to in-application assistance.'').
                 \29\ AAP Comments, at 4; MPAA Comments, at 2-3 (Jan. 15, 2019).
                 \30\ AMI Comments, at 3 (Jan. 15, 2019).
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                 Other commenters recommended the development of new in-application
                assistance tools. For example, GAG suggested that the Office
                incorporate frequently asked questions and answers ``throughout the
                registration application stream (possibly within an interactive widget
                that won't clutter or obstruct the interface).'' \31\ The New York
                Intellectual Property Law Association (``NYIPLA'') urged the Office to
                provide ``more information and guidance in the online forms
                themselves,'' and suggested that the USPTO's ``method of providing
                links to pop-up windows with additional information provides a good
                model for how information can be presented to users.'' \32\
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                 \31\ GAG Comments, at 3.
                 \32\ NYIPLA Comments, at 2 (Jan. 15, 2019).
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                 The Office will pursue both approaches. The Office is updating its
                website to provide additional guidance that applicants can consult
                before they begin or while they are completing an application. In
                addition to improving existing FAQs, the Office is updating its
                questionnaires and adding video tutorials. The Office also will request
                development of new tools for in-application assistance, such as the
                tiered system proposed in the 2018 NOI, subject to usability testing
                during the OCIO's ECS development.
                (2) Electronic Applications
                 The 2018 NOI sought comment on whether the Office should switch to
                a strictly-electronic system. After considering the feedback received,
                the Office will continue to encourage the use of electronic
                applications over paper forms by differentiating the fees for the
                standard and paper applications. But it will not, at this time,
                eliminate paper applications.
                 While paper applications remain the most cumbersome for the Office
                to ingest and examine,\33\ these forms serve populations that do not
                have access to a computer or the internet. The Office notes GAG's
                comment that ``there will always be a certain portion of the population
                who, for various reasons (such as disability, distance from libraries,
                time constraints, etc.) are unable to avail themselves of those
                resources.'' \34\ Additionally, several commenters expressed concerns
                about potential technology failures.\35\ The 2018 NOI also sought input
                on whether to switch to electronic-only payment methods, eliminating
                the instances where payments may be made by cash or check. After
                consideration of these comments and review of the various regulatory
                provisions regarding payments,\36\ the Office has determined to issue a
                separate notice to discuss proposed changes to streamline and harmonize
                its payment processing rules. The Office may separately consider
                questions related to the feasibility of subscription pricing under its
                current statutory authority.
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                 \33\ See 83 FR at 52338 (noting that ``a significant portion of
                claims submitted on paper forms require correspondence or other
                action from the Office, which further increases pendency times and
                contributes to the overall backlog of pending claims.'').
                 \34\ GAG Comments, at 4.
                 \35\ AIPLA Comments, at 2 (``[T]echnology has limitations and
                suffers downtime and failures. It is often critically important that
                applicants file within strict time requirements to enforce their
                rights in court (17 U.S.C. 411) or avoid losing statutory benefits
                (17 U.S.C. 412).''); GAG Comments, at 4 (``Paper applications . . .
                fill in the gap when a system outage or government shutdown make the
                eCO system unavailable.''); NMPA Comments, at 6 (``[O]ur members who
                opt for the paper application largely do so because of negative
                experiences with the electronic system or interfering outages. Our
                members have found paper applications a useful backup option for
                when the electronic system is down.'').
                 \36\ See, e.g., 37 CFR 201.6(a), 201.33(e)(2), 201.39(g)(3),
                202.12(c)(2)(ii), 202.23(e)(2).
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                (3) Electronic Certificates
                 Upon approving an application for registration of a copyright
                claim, the Office issues a certificate of registration.\37\ While the
                Office has traditionally issued certificates in paper form, the 2018
                NOI proposed providing electronic certificates in a secure form to
                ensure authenticity. The cost of the electronic certificate would be
                included in the registration fee. The Office proposed that it would
                provide paper certificates upon request for an additional fee.\38\
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                 \37\ 17 U.S.C. 410(a), 708(a)(1).
                 \38\ 83 FR at 52338-39; see 37 CFR 201.3(c)(14) (2019) (fee for
                obtaining an additional certificate).
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                 All commenters supported the issuance of electronic
                certificates.\39\ In response to the Office's explanation that printing
                paper certificates ``requires a substantial amount of resources both in
                terms of employee compensation and the cost of maintaining printing
                equipment,'' \40\ AMI agreed that ``resources currently utilized for
                printing and mailing paper certificates should be redirected to other
                services, such as better application assistance.'' \41\ The Office
                accordingly will issue electronic certificates in the new ECS as a
                matter of course. The Office intends to offer paper certificates for an
                additional fee.\42\ In addition, as noted below, the Office has
                determined that it is appropriate for these electronic certificates to
                be viewable in the public record.
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                 \39\ See, e.g., Author Services, Inc. Comments, at 2 (Jan. 8,
                2019) (``We support this proposal''); Copyright Alliance Comments,
                at 9 (``The Copyright Alliance supports the Office's proposal to
                issue electronic certificates in lieu of paper copies and only offer
                paper certificates for an additional fee''); GAG Comments, at 4
                (``We agree with the Copyright Office's proposal that registration
                certificates be supplied as electronic documents with validating
                watermarks, etc.''); MPAA Comments, at 5 (``The MPAA has no
                objection to the Office issuing electronic certificates in the
                normal course, with paper certificates available for an additional
                fee.''); News Media Alliance (``NMA'') Comments, at 4 (Jan. 15,
                2019) (``The Alliance supports the issuance of electronic
                certificates, particularly if it would expedite the application
                process and the resulting savings are used to offset costs to the
                registrants.'').
                 \40\ 83 FR at 52338.
                 \41\ AMI Comments, at 4.
                 \42\ The Office will issue a notice regarding any additional
                fees. See 17 U.S.C. 708.
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                 Some commenters expressed concern about whether courts would accept
                [[Page 12707]]
                electronic certificates.\43\ The Office will request implementation of
                visual markers, such as watermarks, to indicate that an Office-issued
                electronic registration certificate is indeed authentic.
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                 \43\ Copyright Alliance Comments, at 9; MPAA Comments, at 5-6;
                NMPA Comments at 7; NYIPLA Comments, at 2; RIAA Comments, at 3.
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                (B) Application Information: The Information Requested on the
                Application for Registration
                (1) Simplifying the Authorship Statement
                 The Copyright Act does not require registration applicants to
                describe the type of work for which registration is sought, except in
                the case of a compilation or derivative work.\44\ But the Act permits
                the Register to require ``any other information'' that bears ``upon the
                preparation or identification of the work or the existence, ownership,
                or duration of the copyright.'' \45\ Thus, under current practices,
                ``[t]o register a work of authorship, the applicant must file an
                application that clearly identifies the copyrightable authorship that
                the applicant intends to register.'' \46\ In the online application,
                the applicant can identify that authorship by ``checking one or more of
                the boxes in the Author Created field that accurately describe the
                authorship.'' \47\ The options available vary depending on the type of
                application in use (e.g., Literary, Visual Arts, or Performing Arts).
                If registering a literary work, the options are ``text,'' ``computer
                program,'' ``photograph(s),'' or ``artwork.'' If registering a visual
                arts work, the options include ``photograph'' and ``two-dimensional
                artwork,'' among others. If registering a performing arts work, the
                options include ``music,'' ``lyrics,'' ``other text (includes script,
                screenplay, dramatic work),'' and ``musical arrangement.'' As a result,
                works are described by their individual elements (e.g., text, lyrics,
                or two-dimensional artwork), rather than by a holistic description of
                the work such as ``children's book with illustrations,'' ``research
                paper,'' or ``craft book with photographs,'' which may be more helpful
                for future identification purposes. Seeking to capture a more complete
                description of works submitted for registration, the Office proposed to
                adjust the Author Created section and ask applicants to identify the
                work as a whole instead of the work's individual elements.\48\
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                 \44\ See 17 U.S.C. 409(1)-(10).
                 \45\ Id. at 409(10).
                 \46\ U.S. Copyright Office, Compendium of U.S. Copyright Office
                Practices sec. 618.1 (3d ed. 2017) (``Compendium (Third)'').
                 \47\ Id. at sec. 618.4(A).
                 \48\ 83 FR at 52339-40.
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                 Although the Office did not receive comments objecting to the
                adjustment of this requirement per se, several commenters opposed the
                wholesale elimination of the online application's Author Created
                section.\49\ For example, AAP argued that it is ``helpful to the public
                record to have an applicant name the authorship, what is being
                registered, what is being disclaimed, and other such pertinent
                information.'' \50\
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                 \49\ See, e.g., AIPLA Comments, at 3-4; Authors Guild, Inc.
                (``Authors Guild'') Comments, at 3 (Jan. 15, 2019).
                 \50\ AAP Comments, at 5.
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                 The Office agrees that authorship descriptions provide pertinent
                information concerning registered works, and does not intend a complete
                removal of the Author Created section. Rather, the Office will request
                that the OCIO explore two complementary methods to obtain more complete
                and specific descriptions of works. First, the Office will request
                exploration of using tiers of descriptions that permit the applicant to
                gradually narrow the identification of their work using a more expanded
                decision tree format. Under this approach, the system would allow
                applicants to identify the work submitted for registration by using
                general and specific pre-populated descriptions, as well as a free-form
                space allowing applicants to provide more descriptive, non-legal
                information. General descriptions would include the categories of
                authorship set forth in section 102 of the Copyright Act, while
                specific descriptions could include particular types of works within
                those categories--for example, ``novel,'' ``poem,'' ``article'' or
                ``podcast.'' After testing the feasibility of this approach, the Office
                will provide guidance regarding whether this method is preferable to
                the current format.
                 Second, and potentially additive of the first approach, the Office
                will request that the OCIO investigate developing a table of
                crowdsourced descriptions, using as a model the USPTO's Trademark
                Identification Manual, which provides users with acceptable
                identifications of goods and services for use in trademark
                applications.\51\ This option would allow examiners to curate
                acceptable descriptions encountered through the examination process to
                add to the database, and for an applicant to rely upon this list for
                guidance in describing their work. This would allow the Office to
                consider and adopt industry-specific or specialized descriptors for
                applications on a going-forward basis.
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                 \51\ See USPTO, Trademark ID Manual, https://idm-tmng.uspto.gov/id-master-list-public.html.
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                 For paper applications, the Office will permit the examiner to
                provide a description of the work submitted for registration where no
                description is provided by the applicant. Although commenters were not
                supportive of examiners providing work descriptions, arguing that it
                would ``likely increase the workload of examiners and could have the
                effect of lengthening registration times and increasing costs,'' \52\
                on average, paper applications comprise only 4% of all applications
                that the Office receives.\53\ A common error that the Office encounters
                is a blank authorship section. Allowing examiners to provide this
                information would improve efficiency by reducing the correspondence
                required to obtain omitted authorship statements, which, as the Office
                has noted, ``imposes significant burdens on the Office's limited
                resources, and has had an adverse effect on the [pendency of]
                examination of claims submitted on electronic forms.'' \54\
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                 \52\ NMPA Comments, at 11.
                 \53\ U.S. Copyright Office, Registration Processing Times,
                https://www.copyright.gov/registration/docs/processing-times-faqs.pdf.
                 \54\ 83 FR at 52338.
                ---------------------------------------------------------------------------
                (2) Derivative Works
                 For a compilation or derivative work, the Copyright Act requires
                copyright registration applicants to identify ``any preexisting work or
                works that it is based on or incorporates'' and to provide ``a brief,
                general statement of the additional material covered by the copyright
                claim being registered.'' \55\ Generally, the Office attempts to obtain
                this information in two steps. First, the applicant must ``identify the
                new authorship that the applicant intends to register'' by checking one
                or more boxes that appear under the heading ``Author Created'' in the
                online application that describe the new material the applicant intends
                to register, or by providing a descriptive statement in the ``Nature of
                Authorship'' space on the paper application.\56\ Second, if the
                derivative work contains an appreciable amount of preexisting material
                that was previously published, previously registered, in the public
                domain, or owned by a third party, the applicant must identify that
                material by checking one or more boxes in the ``Material Excluded''
                field of the online application or by providing a brief statement in
                the corresponding section of the paper application.\57\ This
                [[Page 12708]]
                method can lead to gaps in the public record because it ``encourage[s]
                applicants to identify individual elements of the work that should be
                excluded from the claim,'' but it does not require applicants to
                identify the preexisting work itself.\58\ Further, in the Office's
                experience, the checkboxes provided on the application may limit
                applicants' ability to fully describe the nature of their claims,
                leading to errors in identifying new or preexisting material. For
                example, using the checkboxes, applicants often mark the ``Material
                Included'' as ``text'' and the ``Material Excluded'' also as ``text.''
                These descriptions do not add any meaningful information to users of
                the public record.
                ---------------------------------------------------------------------------
                 \55\ 17 U.S.C. 409(9).
                 \56\ Compendium (Third) sec. 618.5.
                 \57\ Id.
                 \58\ 83 FR at 52341.
                ---------------------------------------------------------------------------
                 To avoid this result, the 2018 NOI proposed requiring applicants to
                identify explicitly whether a work submitted for registration is a
                derivative work. If the work is identified as derivative, applicants
                would be directed to identify, in their own words, any elements that
                should be excluded from the claim. And, assuming that the applicant
                intends to register all copyrightable aspects of the work that have not
                been expressly disclaimed, the applicant would not be required to
                identify the new material that should be ``included'' in the claim.\59\
                ---------------------------------------------------------------------------
                 \59\ Id.
                ---------------------------------------------------------------------------
                 While most commenters acknowledged that it would benefit the public
                record to require applicants to explicitly identify derivative works
                submitted for registration,\60\ some were concerned that such a
                requirement would cause confusion. For example, the Copyright Alliance
                had ``concerns that novice applicants might be confused about how to
                answer such a question,'' believing that it ``would require an
                understanding of the nuance between `transformation' as it is used in
                fair use, and `transform' as it is used to define a derivative work.''
                \61\ GAG likewise noted that ``novice users (and even experience[d]
                users) are often tripped up in interpreting whether a work is
                derivative.'' \62\ Instead of asking whether a work is a derivative
                work, commenters argued that the Office should ask ``whether
                preexisting works have been used, and if yes, what those works are.''
                \63\ Some commenters also expressed concern that eliminating the
                requirement to identify the new material that should be included in the
                claim would ``wreak havoc with the Copyright Office's objective to
                produce as accurate a public record as possible.'' \64\
                ---------------------------------------------------------------------------
                 \60\ See, e.g., AIPLA Comments, at 4 (``AIPLA believes that
                applicants should be required to identify whether the work submitted
                for registration is a derivative work''); AMI Comments, at 6 (``The
                AMI would not object to asking applicants to affirmatively state
                whether a work submitted is derivative provid[ed] the application
                form makes it crystal clear as to what constitutes a derivative
                work.''); NYIPLA Comments, at 3 (``It is often helpful to know
                whether a registered work is a derivative work'').
                 \61\ Copyright Alliance Comments, at 17.
                 \62\ GAG Comments, at 7.
                 \63\ Id.; see American Bar Association Section of Intellectual
                Property Law (``ABA-IPL'') Comments, at 5 (Jan. 9, 2019) (``The
                Section suggests that a simpler process for soliciting factual
                information about preexisting materials would be to include
                questions requiring `yes/no' responses'').
                 \64\ AAP Comments, at 6.
                ---------------------------------------------------------------------------
                 Others supported this proposed approach. AMI opined that
                eliminating ``cumbersome checkboxes'' and allowing applicants ``to more
                easily explain in their own words the elements that are pre-existing
                versus the `new material to be included' '' would simplify the
                registration process for such works.\65\ AIPLA agreed that ``asking the
                applicant to identify the new authorship is unnecessary . . . and that
                the Office should assume that the applicant intends to register all
                copyrightable aspects of the work.'' \66\
                ---------------------------------------------------------------------------
                 \65\ AMI Comments, at 5 (citation omitted).
                 \66\ AIPLA Comments, at 4; see also New Media Rights (``NMR'')
                Comments, at 17 (Jan. 15, 2019) (``If the user disclaims content,
                presumably the rest of the protectable audiovisual work is original
                content created by the author, so the `New Material Included'
                category does not seem necessary or relevant unless the work being
                registered is a new edition of a previously registered work (which
                is a very specific subset of content).''); AAP Comments, at 5 (``AAP
                members are in favor of asking applicants to explicitly identify
                whether a work submitted for registration is a derivative work and
                to identify, in their own words, any elements that should be
                excluded from the claim.'').
                ---------------------------------------------------------------------------
                 After reviewing the comments, the Office continues to believe that
                the current identification process should be simplified, but agrees
                that use of the term ``derivative work'' may cause confusion. Instead,
                the Office will provide a business requirement that the revised
                electronic application ask applicants, in plain language, about the
                facts relating to the authorship of the work (e.g., Is the work based
                on one or more preexisting works? Does the work incorporate any
                preexisting work?). The Office will request that the system allow
                applicants to identify any elements that should be excluded from the
                claim using their own words, rather than a set of predetermined
                checkboxes. This approach is intended to streamline the process by
                which applicants can disclaim preexisting material.
                (3) Simplifying the Transfer Statement
                 An application for registration must identify the copyright
                claimant.\67\ The ``claimant'' is either the author(s) of the work
                submitted for registration,\68\ or an individual or organization that
                owns all of the rights under copyright.\69\ To register a claim of
                copyright, ``if the copyright claimant is not the author,'' the
                copyright registration application must include ``a brief statement of
                how the claimant obtained ownership of the copyright.'' \70\ This
                ``brief statement'' is termed a transfer statement. Further, the
                Copyright Act specifies that copyright may be transferred (1) ``by any
                means of conveyance,'' (2) ``by will or . . . by the applicable laws of
                intestate succession,'' or (3) ``by operation of law,'' and so the
                transfer statement must fit within these statutory guidelines.\71\
                ---------------------------------------------------------------------------
                 \67\ 17 U.S.C. 409(1).
                 \68\ Id. at 201(a) (``Copyright in a work protected under this
                title vests initially in the author or authors of the work. The
                authors of a joint work are coowners of copyright in the work.'').
                 \69\ Id. at 201(d)(1) (``The ownership of a copyright may be
                transferred in whole or in part by any means of conveyance or by
                operation of law, and may be bequeathed by will or pass as personal
                property by the applicable laws of intestate succession.''); 37 CFR
                202.3(a)(3) (defining claimant as the author of a work or the person
                or organization that has obtained all rights under copyright
                initially belonging to the author).
                 \70\ 17 U.S.C. 409(5).
                 \71\ Id. at 201(d)(1).
                ---------------------------------------------------------------------------
                 As the 2018 NOI explained, the current online registration
                application allows applicants to provide a transfer statement by
                selecting one of three options in a drop-down menu marked ``Transfer
                Statement.'' The three options are ``By written agreement,'' ``By
                inheritance,'' and ``Other.'' The Compendium of U.S. Copyright Office
                Practices provides that ``[i]f the claimant obtained the copyright
                through an assignment, contract, or other written agreement, the
                applicant should select `By written agreement.' '' \72\ And ``[i]f the
                claimant obtained the copyright through a will, bequest, or other form
                of inheritance, the applicant should select `By inheritance.' '' \73\
                The applicant may select ``Other'' and provide a more specific transfer
                statement in a blank space marked ``Transfer Statement Other'' if ``By
                written agreement'' or ``By inheritance'' do not fully describe the
                transfer.
                ---------------------------------------------------------------------------
                 \72\ Compendium (Third) sec. 620.9(A).
                 \73\ Id.
                ---------------------------------------------------------------------------
                 In the 2018 NOI, the Office proposed eliminating the ``Other''
                option both to avoid confusion among applicants and to better align the
                process with the statutory text. Applicants often provide conflicting
                information when they select the ``Other'' option, which requires
                examiners to expend time to correspond with applicants to correct the
                application and delays the resolution of claims. Because the methods of
                transfer are limited by section 201, practically
                [[Page 12709]]
                speaking, the only correct statement that can be provided in the
                ``Other'' space is a transfer occurring ``by operation of law,'' a
                legal concept referring to rights that arise under specific
                contingencies such as by court-ordered or bankruptcy-related transfers,
                certain forms of acquisitions such as stock sales, or explicit
                agreements providing for joint ownership with rights of
                survivorship.\74\ The Office accordingly proposed to replace the
                ``Other'' option with ``By operation of law.'' \75\
                ---------------------------------------------------------------------------
                 \74\ See David Nimmer & Melville Nimmer, 3 Nimmer on Copyright
                sec. 10.03(A)(6) (2019).
                 \75\ 83 FR at 52341.
                ---------------------------------------------------------------------------
                 Most commenters supported the Office's proposal, agreeing that it
                would ``simplify and clarify the process for completing transfer
                statements.'' \76\ Others, however, expressed concern about the
                proposed change. For example, the Authors Guild argued that the ``means
                of acquiring ownership other than by written transfer or inheritance
                should be spelled out in a dropdown menu in plain English and
                explained'' because `` `By operation of law' is a broad and legal term
                that non-lawyers won't necessarily understand.'' \77\ AAP opposed
                removing the ``Transfer Statement Other'' field, recommending ``a
                flexible and open format to accommodate sufficient explanation in cases
                of complicated transfer statements'' to support a ``robust and useful
                public record.'' \78\
                ---------------------------------------------------------------------------
                 \76\ NYIPLA Comments, at 3; see also AMI Comments, at 6 (``The
                AMI supports simplification of transfer statements.'');
                International Trademark Association (``INTA'') Comments, at 7 (Jan.
                10, 2019) (``[S]ince Copyright Act Section 201(d)(1) provides for
                transfer of an author's interest only by written agreement,
                inheritance, or operation of law, limiting the transfer statement to
                these three categories is advisable.''); MPAA Comments, at 9 (``The
                only options that should be available to registrants in describing a
                transfer of ownership are those mentioned in 17 U.S.C. 201: `by
                written agreement,' `by inheritance,' or `by operation of law.'
                There is no statutory justification for the `Other' option, which
                should be eliminated.'').
                 \77\ Authors Guild Comments, at 4.
                 \78\ AAP Comments, at 6.
                ---------------------------------------------------------------------------
                 As several commenters pointed out, copyright transfer remains a
                confusing area of law for many applicants.\79\ While it might at first
                seem that giving applicants more space to describe their particular
                transfer scenario would enhance the public record, the Office's
                experience indicates that an open format text box can give rise to
                inconsistent information, while increasing registration processing time
                due to the need for correspondence. Therefore, the Office tentatively
                concludes it would be optimal to eliminate the ``Other'' field and
                restrict the available fields to ``By written agreement,'' ``By
                inheritance,'' and ``By operation of law'' to improve efficiency.
                Rather than requiring applicants to describe the transfer in their own
                words, the Office intends to provide guidance, such as information
                icons or other in-application assistance, to provide a clear definition
                of each transfer statement option for applicants, including, in
                particular, to explain what instances may constitute a transfer ``by
                operation of law.''
                ---------------------------------------------------------------------------
                 \79\ See Authors Guild Comments, at 4; Copyright Alliance
                Comments, at 17; GAG Comments, at 7; INTA Comments, at 7.
                ---------------------------------------------------------------------------
                 The Office is also exploring the value of providing a space for
                applicants to add any recordation document numbers that support the
                transfer statement. While a copy of an agreement, conveyance, or other
                legal instrument is not an acceptable substitute for a transfer
                statement,\80\ if such an instrument has been recorded with the Office,
                the relevant recordation information may be valuable to the
                registration record. Should this option prove feasible, the Office will
                provide in-application guidance on relevant document recordation
                topics.
                ---------------------------------------------------------------------------
                 \80\ Compendium (Third) sec. 620.10(A).
                ---------------------------------------------------------------------------
                (4) In-Process Corrections
                 The current online registration system does not permit applicants
                to make manual corrections once an application is submitted to the
                Office. The applicant must contact the Public Information Office to ask
                the Office to make any necessary corrections. For the new ECS, the
                Office proposed removing this limitation and permitting applicants to
                make changes to pending applications at any point before an examiner
                opens the application for review.\81\
                ---------------------------------------------------------------------------
                 \81\ 83 FR at 52341.
                ---------------------------------------------------------------------------
                 All commenters supported this proposal,\82\ but several requested
                that the ECS warn applicants when an amendment would change a work's
                Effective Date of Registration.\83\ ImageRights International, Inc.
                (``ImageRights'') recommended that the system ``present a schedule of
                what types of changes can be made without altering the Effective Date
                of Registration and which changes would change the Effective Date.''
                \84\
                ---------------------------------------------------------------------------
                 \82\ See, e.g., AIPLA Comments, at 5 (``AIPLA supports
                permitting applicants to make edits to pending applications in most
                circumstances.''); AAP Comments, at 6 (``AAP members generally
                support the proposal of allowing applicants to make in-process edits
                to open cases prior to the examination of application materials.'').
                 \83\ AAP Comments, at 6 (``We trust the Office would establish
                clear parameters and practices as to when such corrections would
                trigger a change in the effective date of registration.'');
                Copyright Alliance Comments, at 18 (``The Office should permit
                applicants to make in-process edits to open cases at any point prior
                to the examination of the application materials, provided that the
                Office clearly warns applicants prior to making changes that a
                modification could alter the effective date depending on the type of
                change and explains the types of changes that would result in change
                in the effective date.'').
                 \84\ ImageRights Comments, at 6 (Jan. 15, 2019).
                ---------------------------------------------------------------------------
                 In general, to establish an Effective Date of Registration, the
                Office must receive an acceptable application, a complete deposit copy,
                and the appropriate filing fee.\85\ The Effective Date of Registration
                is the date the Office receives all three of these elements, but
                ``[w]here the three necessary elements are received at different times
                the date of receipt of the last of them is controlling.'' \86\ The
                Compendium sets forth the minimum requirements for an acceptable
                application, deposit copy, and filing fee.\87\ In consideration of the
                comments, the Office envisions that the new ECS will incorporate these
                current rules to warn applicants when an amendment would alter the
                Effective Date of Registration.
                ---------------------------------------------------------------------------
                 \85\ Compendium (Third) sec. 625.
                 \86\ H.R. Rep. No. 94-1476, at 157 (1976), reprinted in 1976
                U.S.C.C.A.N. 5659, 5773.
                 \87\ Compendium (Third) sec. 625.
                ---------------------------------------------------------------------------
                (5) Application Programming Interfaces (``APIs'')
                 A copyright system of the twenty-first century demands flexibility,
                agility, and adaptability to technological advancements. The Office
                believes that the use of APIs--interfaces that permit communication
                between two systems or software programs--could improve the
                registration system by enabling programs used in the process of
                creating works to submit copyright registration applications or extract
                data from the online public record. To explore possible uses of this
                technology in the new ECS, the Office invited comment on how it could
                use APIs to integrate external data into the registration system or
                allow parties to export internal data from the Office's registry. The
                Office also inquired about relevant design considerations, such as
                establishing a trusted provider framework to minimize spam submissions
                and deter predatory behavior.\88\ Commenters generally agreed that
                using APIs would benefit registration applicants and users of the
                online public record,\89\ although some
                [[Page 12710]]
                commenters urged the Office to provide adequate safeguards to protect
                the security of the data and to guard against abuses by bad actors.\90\
                With stakeholder support, the Office will continue to explore and
                clarify its business needs related to the use of APIs for two purposes:
                (1) Ingesting data into the Office online registration system, and (2)
                extracting information from the online public record. Of course, any
                new functionality must provide appropriate security for all relevant
                data. The Office will continue to communicate this need to the OCIO.
                ---------------------------------------------------------------------------
                 \88\ 83 FR at 52342-43.
                 \89\ Artists Rights Society Comments, at 4 (Jan. 10, 2019)
                (``ARS . . . would welcome the opportunity to develop in cooperation
                with the Office an API that would be tailored to the needs of ARS
                members so that when members sign up with ARS . . . they also might
                be able to complete an electronic registration form.''); CVA
                Comments, at 27-28 (encouraging the Office ``to develop robust
                Application Programming Interfaces (APIs) that will allow third-
                party image management software to interface directly with the
                Copyright Office's registration system''); Copyright Alliance
                Comments, at 21 (expressing support for ``allowing third-parties to
                interoperate with the Office's API in a way that would integrate
                registration into a creator's workflow to streamline and simplify
                the registration process''); GAG Comments, at 8 (expressing support
                for the ``integration of APIs into the registration system so that
                registration becomes part of a creator's workflow'').
                 \90\ See, e.g., Copyright Alliance Comments, at 23 (urging the
                Office to ``create terms of service for access to its API,'' which
                would allow the Office ``to block access . . . [by] third parties
                who abuse the APIs'' though spam submissions or predatory behavior);
                PPA Comments, at 16 (stating that the Office must ensure that ``the
                process is secure and able to handle the influx of data'').
                ---------------------------------------------------------------------------
                 Initially, the Office will prioritize investigation of ways to
                allow for the transmission of data between the registration system and
                the database of musical works information that will be administered by
                the Mechanical Licensing Collective (``MLC'') pursuant to the Orrin G.
                Hatch-Bob Goodlatte Music Modernization Act.\91\ The MLC database will
                contain information relating to musical works (and shares of such
                works) and, to the extent known, the identity and location of the
                copyright owners of such works and the sound recordings in which the
                musical works are embodied.\92\ To reduce the incidence of unmatched
                works, where the copyright owner has not been identified or located,
                the MLC will operate a claiming process by which musical work copyright
                owners may identify their ownership interests in a musical work
                underlying a specific sound recording, to receive accrued royalties for
                the usage of that musical work.\93\
                ---------------------------------------------------------------------------
                 \91\ Public Law 115-264, 132 Stat. 3676 (2018).
                 \92\ 17 U.S.C. 115(d)(3)(C).
                 \93\ Id. at 115(d)(3)(I), (J)(iii); see id. at 115(e)(35).
                ---------------------------------------------------------------------------
                 By law, the Copyright Office may access the database in a bulk,
                machine-readable format, although the Office may not treat the database
                or any of its information therein as a Government record.\94\ As some
                have suggested,\95\ providing a method of access between the copyright
                and MLC registration systems could permit a copyright owner to verify
                or update ownership information with respect to musical works listed in
                the MLC database alongside the process of completing a copyright
                registration application for that work, or vice versa. The Office has
                concluded that the MLC database represents an appropriate starting
                point for API development. While the Office will prioritize this
                aspect, the Office will also work with the OCIO to explore additional
                avenues to facilitate the ingestion and exportation of data through
                APIs, while ensuring the integrity of registration records and
                safeguarding against abuses.
                ---------------------------------------------------------------------------
                 \94\ Id. at 115(d)(3)(E)(v).
                 \95\ David C. Lowery, Simplifying Registration and Costs for
                MLC, The Trichordist (Nov. 6, 2019), https://thetrichordist.com/2019/11/06/simplify-registration-and-costs-for-mlc/ (``It seems like
                a simple solution for the Copyright Office to harmonize [the online
                registration system and the MLC database] to . . . have a check box
                to allow you to sign up with the MLC.'').
                ---------------------------------------------------------------------------
                (C) Public Record: How Users Engage and Manage Copyright Office Records
                (1) The Online Registration Record
                 The Copyright Act charges the Copyright Office with ensuring ``that
                records of deposits, registrations, recordations, and other actions
                taken under this title are maintained'' and are ``open to public
                inspection.'' \96\ The 2018 NOI proposed to expand the online public
                record to include records of pending applications, refusals, closures,
                appeals, and correspondence for completed claims.
                ---------------------------------------------------------------------------
                 \96\ 17 U.S.C. 705.
                ---------------------------------------------------------------------------
                 This proposal received significant support from many commenters.
                For example, the American Association of Law Libraries (``AALL'')
                supported ``publishing refused registration application records, full
                versions of correspondence records, and associated appeal records in
                the online public record because we believe it would help the public
                better understand the originality requirement in copyright law and
                assist those who wish to register a claim to a copyright understand the
                contours of what `constitute[s] copyrightable subject matter.' '' \97\
                Similarly, AIPLA noted that ``the need for full information regarding
                an application and registration is often crucial for litigation,
                licensing, and corporate diligence, among other circumstances.'' \98\
                ---------------------------------------------------------------------------
                 \97\ AALL Comments, at 1 (Jan. 14, 2019) (citing 17 U.S.C.
                410(b)).
                 \98\ AIPLA Comments, at 6.
                ---------------------------------------------------------------------------
                 Some commenters, however, expressed concern that records of
                correspondence may expose personally identifiable information or
                informal communications that applicants may not wish to make public.
                Explaining that ``[c]orrespondence between applicants and the Office is
                often informal,'' AAP argued that including such materials ``would not
                be appropriate [or] useful for the Public Record and could be misused
                by persons who have no claim to the work in question.'' \99\ Other
                commenters argued that the public record should be limited to records
                of what has been registered by the Copyright Office.\100\ NMPA, for
                example, contended that ``[o]nly a subset of copyrights would benefit
                from the inclusion of . . . additional information in the Online Public
                Record'' and that ``[i]ncluding large amounts of administrative
                information concerning a registration would likely slow the system down
                and be an inefficient use of the Office's resources.'' \101\
                ---------------------------------------------------------------------------
                 \99\ AAP Comments, at 7.
                 \100\ See, e.g., RIAA Comments, at 8 (``The online public record
                should support its primary purpose to notify the public of which
                works have been registered, and not be appended in a manner that
                detracts or dilutes from this important function.'').
                 \101\ NMPA Comments, at 17-18.
                ---------------------------------------------------------------------------
                 Current law and regulations require the Office to make available
                for public inspection any ``[o]fficial correspondence, including
                preliminary applications, between copyright claimants or their agents
                and the Copyright Office, and directly relating to a completed
                registration, a recorded document, a rejected application for
                registration, or a document for which recordation was refused.'' \102\
                Further, the current registration application displays a privacy notice
                stating that the information collected for registration ``will appear
                in the Office's online catalog.'' \103\ Given that registration records
                are already available for public inspection and copying,\104\ the
                Office does not see a persuasive basis for categorically excluding them
                from online availability, although the Office will approach historical
                materials sensitively to address any potential notice or privacy
                considerations.
                [[Page 12711]]
                Expanding the online public record to include these materials would
                advance the Office's goal to ``[e]xpand access to Copyright Office
                records'' and ``[e]nhance services'' to make it ``easier and more
                convenient for users to transact business with the Copyright Office.''
                \105\ As such, on a prospective basis, the Office will request that the
                ECS include records of pending applications, refusals, closures,
                appeals, and correspondence for completed claims in the new online
                public record. The Office's PII removal rule will remain in place to
                provide for removal of extraneous PII from the public record upon
                request.\106\
                ---------------------------------------------------------------------------
                 \102\ 37 CFR 201.2(c)(1); see also 17 U.S.C. 705.
                 \103\ U.S. Copyright Office, eCO Registration System Standard
                Application, https://eco.copyright.gov/ (``Privacy Act Notice:
                Sections 408-410 of title 17 of the United States Code authorize the
                Copyright Office to collect the personally identifying information
                requested on this form in order to process the application for
                copyright registration. By providing this information you are
                agreeing to routine uses of the information that include publication
                to give legal notice of your copyright claim as required by 17
                U.S.C. 705. It will appear in the Office's online catalog. If you do
                not provide the information requested, registration may be refused
                or delayed, and you may not be entitled to certain relief, remedies,
                and benefits under the copyright law.'').
                 \104\ Compendium (Third) sec. 2407.1(B)(1).
                 \105\ U.S. Copyright Office, Strategic Plan 2019-2023,
                Copyright: The Engine of Free Expression 13 (2019), https://www.copyright.gov/reports/strategic-plan/USCO-strategic2019-2023.pdf.
                 \106\ See 37 CFR 201.2(f).
                ---------------------------------------------------------------------------
                 Similarly, the Office will work with the OCIO to make digital
                copies of registration certificates available in the online public
                record.
                (2) Linking Registration and Recordation Records
                 Arising out of historical practice, registration and recordation
                records are currently maintained as discrete data sets. Because these
                records are not linked, it can be difficult to identify chain-of-title
                information for particular works contained in the Office's records. All
                commenters supported the Office's proposal to link registration and
                recordation records, so that information about registered claims,
                recorded transfers, and/or other chain of title information can be
                viewed together to facilitate access to information about copyrighted
                works, including updated ownership information.\107\
                ---------------------------------------------------------------------------
                 \107\ AALL Comments, at 3 (noting that the proposal ``would
                assist users who are attempting to obtain permission to use a work
                with accurately identifying and contacting the current copyright
                owner''); ABA-IPL Comments, at 7 (``The Section strongly supports
                connecting registration and recordation records.''); Authors
                Alliance Comments, at 5 (Jan. 15, 2019) (noting that the proposal
                would ``increase[] the likelihood that users will be able to locate
                current and accurate contact information for copyright holders,
                better facilitating licensing and permissions requests''); INTA
                Comments, at 15 (expressing support for ``provid[ing] chain of title
                information''); NMPA Comments, at 18 (``The registration and
                recordation systems should be fully integrated and should be part of
                the same database.''); Nanette Petruzzelli Comments, at 5 (Jan. 14,
                2019) (supporting the proposal so that ``public inquiry about the
                current copyright status of a work can be found in one record/
                file'').
                ---------------------------------------------------------------------------
                 Because the registration and recordation processes are voluntary,
                however, commenters also highlighted some areas of caution, which the
                Office itself is taking into account when developing requirements for
                the new ECS. For example, RIAA noted that while linking records would
                be useful, it could ``create confusion where the records are incomplete
                or the chain of title is unclear.'' \108\ RIAA also expressed concern
                about ``what legal presumptions may be made based on the chain of title
                in a recordation record where there is no obligation for a subsequent
                rights holder to file a transfer or security interest with the
                Office.'' \109\ The MPAA cautioned that the Office should not ``itself
                engage in chain-of-title analysis.'' \110\
                ---------------------------------------------------------------------------
                 \108\ RIAA Comments, at 8.
                 \109\ RIAA Comments, at 8.
                 \110\ MPAA Comments, at 13.
                ---------------------------------------------------------------------------
                 The Copyright Office appreciates the need for the ECS to clearly
                communicate the limitations of the public record to users of the
                system. Currently, the Office warns that while ``[s]earches of the
                Copyright Office catalogs and records are useful in helping to
                determine the copyright status of a work . . . they cannot be regarded
                as conclusive in all cases.'' \111\ The Office will continue to explore
                ways to minimize confusion on the part of users. For example, the
                Office may request that the ECS begin by linking only future
                registration and recordation records.
                ---------------------------------------------------------------------------
                 \111\ U.S. Copyright Office, Circular 22: How to Investigate the
                Copyright Status of a Work 3 (Feb. 2013), https://www.copyright.gov/circs/circ22.pdf; see also U.S. Copyright Office, Request a Search
                Estimate, https://www.copyright.gov/forms/search_estimate.html.
                ---------------------------------------------------------------------------
                 Second, commenters discussed how the Office should display
                assignment information and documentation within public registration
                records. The ABA-IPL suggested that the USPTO's system, which consists
                of an ``Assignment Abstract of Title'' linked to the database entry for
                a mark identified in a search, could be a model for the Copyright
                Office's system.\112\ The NYIPLA similarly suggested that ``the
                Trademark Office offers a good model in that the application/
                registration data is directly linked to the chain of title
                information.'' \113\ The Office found these comments helpful and hopes
                to work with the OCIO to explore the specific manner of display for the
                new online public record system.
                ---------------------------------------------------------------------------
                 \112\ ABA-IPL Comments, at 7.
                 \113\ NYIPLA Comments, at 5.
                ---------------------------------------------------------------------------
                (3) Unified Case Number
                 The Office currently administers and tracks separate numbers for
                applications, correspondence, and registrations, which creates
                challenges for the Office and users. To streamline identification
                methods, the 2018 NOI proposed to unify the Office's identification
                numbers to create a clear relationship between an application for
                registration, any correspondence, and any associated request for
                reconsideration.\114\ There was a general consensus among commenters in
                support of the Office's proposal.\115\
                ---------------------------------------------------------------------------
                 \114\ 83 FR at 52344.
                 \115\ See generally AIPLA Comments, at 7 (``AIPLA strongly
                supports this proposal.''); AAP Comments, at 8 (``AAP members are in
                favor of unified case numbers to track and identify a work or group
                of works through the registration and appeals process''); PPA
                Comments, at 16 (``PPA supports a single case number which remains
                with the application through the registration process and after the
                registration is issued. This will help with tracking and
                consistency.'').
                ---------------------------------------------------------------------------
                 Accordingly, for future applications, the Office would like the
                system to adopt one number for any pending application and registration
                record completed from that application. The Office envisions that the
                number assigned to an application (the ``case number'') and the
                registration number will have an identical base, but the registration
                number will be distinguished by a prefix that indicates the
                administrative class or type of registration. For example, case number
                12345678 for a performing arts work would become PA12345678, if
                registered. To further simplify the registration process, the Office
                will also retire correspondence identification numbers.
                (D) Digital Deposits
                 In the 2018 NOI, the Office requested comment on whether applicants
                should be permitted to submit electronic deposit copies, phonorecords,
                or identifying materials, rather than physical copies or phonorecords,
                unless the Office requests a physical copy.\116\ While commenters
                expressed general support for providing greater flexibility in
                complying with deposit requirements, the comments raised a number of
                concerns. The Library of Congress's Library Services unit expressed
                concern over the potential effect of such a change on Library
                collections. Noting that ``[t]he Library depends on the continuing flow
                of items acquired via Copyright deposit to help build its collection,''
                it noted that ``implementation of this strategy would require that a
                duplicative process be established to obtain deposit copies for the
                Library's collection.'' \117\ Subsequently, in response to a question
                raised by the Senate Judiciary's IP Subcommittee, the Librarian of
                Congress noted that ``a change to a default digital deposit requirement
                would critically affect our ability to serve some of our
                [[Page 12712]]
                largest user groups, either by not meeting their preferences or by
                denying service altogether.'' \118\
                ---------------------------------------------------------------------------
                 \116\ 83 FR at 52344-45.
                 \117\ Library of Congress Library Services Comments, at 1-2
                (Jan. 15, 2019).
                 \118\ Carla Hayden, Librarian of Congress, Responses to
                Questions for the Record, Subcomm. on Intell. Prop. of the S. Comm.
                on the Judiciary at 3-4 (Jan. 7, 2020), https://www.judiciary.senate.gov/imo/media/doc/Hayden%20Responses%20to%20QFRs.pdf.
                ---------------------------------------------------------------------------
                 Other commenters representing copyright owner interests raised
                potential security concerns. For example, the Copyright Alliance
                pointed to the possibility of cyberattacks resulting in unauthorized
                access to deposit copies.\119\ AAP stated that ``[p]ublishers would
                welcome a registration deposit regime that is less burdensome, but only
                if it is operated in a wholly secure IT system and kept wholly separate
                from the collections of the Library and its access or interlibrary
                lending or surplus books policies.'' \120\ In its view, such changes
                are ``premature and will remain so until the Copyright Office is
                permitted and able to develop the necessary IT systems and security.''
                \121\
                ---------------------------------------------------------------------------
                 \119\ Copyright Alliance Comments, at 25.
                 \120\ AAP Comments, at 2.
                 \121\ Id. at 3.
                ---------------------------------------------------------------------------
                 The Copyright Office is committed to pursuing any updates to the
                registration deposit system in a reasonable and conscientious manner.
                At the same time, due to the wide variety of expressive works that can
                be registered, spanning physical and digital formats, from individual
                to large corporate authors, the ECS must be designed in a manner to
                accommodate submission of both physical and electronic deposits.\122\
                Under the current framework, the Office has recently noted that ``[a]ny
                future expansion of electronic deposits to additional categories of
                works will require careful consideration of several factors, including
                the Library's collection needs, technological capabilities, and
                security and access issues.'' \123\ Meanwhile, the Office notes that
                these issues may overlap with ongoing legislative discussion.\124\ The
                Office therefore has concluded that consideration of changes to the
                deposit requirements are beyond the scope of this current notice. As
                noted, however, the Office and the Library will work collaboratively to
                develop alternative deposit options ``that appropriately balance
                security with ease of use. These kinds of important issues will be
                addressed using transparent processes that invite public comment and
                participation.'' \125\
                ---------------------------------------------------------------------------
                 \122\ The current statutory default instructs owners to submit a
                deposit of a complete copy of the work and, for works published in
                the U.S., the best edition of that work (unless regulations permit
                the deposit of alternate identifying material). 17 U.S.C. 407, 408;
                83 FR at 52344. But the statute does not compel authors or
                publishers to create a special copy for the purpose of copyright
                registration or to fulfill the separate obligation under section
                407. See Mandatory Deposit of Electronic-Only Books, 83 FR 16269,
                16274 (notice of proposed rulemaking).
                 \123\ Jody Harry, Chief Financial Officer, U.S. Copyright
                Office, Responses to Questions for the Record, Subcomm. on Intell.
                Prop. of the S. Comm. on the Judiciary at 13 (Dec. 17, 2019),
                https://www.judiciary.senate.gov/imo/media/doc/Harry%20Responses%20to%20QFRs.pdf.
                 \124\ Carla Hayden, Librarian of Congress, Responses to
                Questions for the Record, Subcomm. on Intell. Prop. of the S. Comm.
                on the Judiciary at 3 (Jan. 7, 2020), https://www.judiciary.senate.gov/imo/media/doc/Hayden%20Responses%20to%20QFRs.pdf (responding to question about
                draft legislation on the deposit requirement).
                 \125\ Id.; see also id. at 4 (``The Library would like to work
                closely with the Copyright Office to update the best edition
                statement on a consistent and regular basis.'').
                ---------------------------------------------------------------------------
                II. Additional Subjects of Inquiry
                 In addition to the foregoing practice changes, the Office is
                continuing to consider additional issues raised in the 2018 NOI and now
                seeks further comment on the following topics.
                (A) The Rights and Permissions Field
                 Presently, at the conclusion of an online registration application,
                the applicant is asked to provide Rights and Permissions information,
                which may include ``the name, address, and other contact information
                for the person and/or organization that should be contacted for
                permission to use the work.'' \126\ Currently, applicants may provide
                only one name and address. This information appears in the online
                public record for the work to facilitate licensing and similar
                transactions.\127\ Once a certificate of registration is issued,
                interested parties may update the Rights and Permissions information by
                either (1) requesting that the Office remove certain personally
                identifiable information from the online public record and replace it
                with substitute information,\128\ or (2) submitting an application for
                a supplementary registration.\129\
                ---------------------------------------------------------------------------
                 \126\ Compendium (Third) sec. 622.1. There is no corresponding
                space for providing Rights and Permissions information in a paper
                application.
                 \127\ Id.
                 \128\ 37 CFR 201.2(e)(1); Compendium (Third) sec. 622.1. See
                generally Removal of Personally Identifiable Information from
                Registration Records, 82 FR 9004 (Feb. 2, 2017) (final rule).
                 \129\ 37 CFR 202.6(d), (e); Compendium (Third) sec. 1802.
                ---------------------------------------------------------------------------
                 To achieve a more flexible amendment process, the 2018 NOI proposed
                allowing users to update Rights and Permissions information, as
                necessary, without having to submit a formal written removal request
                and fee and without having to seek a supplementary registration.\130\
                The overwhelming majority of commenters supported this proposal.\131\
                AALL noted that it would ``better ensure that the information remains
                up-to-date, thereby reducing the risk of a work becoming an orphan
                work, encouraging proper attribution by others, and facilitating users
                [in] properly obtaining permission or a license to use a work.'' \132\
                Authors Alliance similarly noted that ``the costs associated with
                updating the Rights and Permissions field discourages users from
                updating contact information, leading to inaccurate records and
                contributing to the orphan works problem.'' \133\
                ---------------------------------------------------------------------------
                 \130\ 83 FR at 52341-42.
                 \131\ ABA-IPL Comments, at 6 (``[T]he Section supports allowing
                registrants to update the Rights and Permissions information for
                their works posted on the public record in a simplified manner'');
                AIPLA Comments, at 5 (``AIPLA supports allowing authorized users to
                make changes to this field''); Authors Alliance Comments, at 4
                (``Authors Alliance supports the Office's efforts to build a
                registration interface that allows users to update Rights and
                Permissions information without having to submit a supplementary
                registration together with the associated fee''); INTA Comments, at
                9 (``INTA strongly supports making the Online Public Record a more
                dynamic system by allowing authorized representatives to update
                rights and permission information''); NMA Comments, at 5 (``The
                Alliance supports the proposal to allow authorized users to make
                changes to the Rights and Permissions field in a completed
                registration'').
                 \132\ AALL Comments, at 3.
                 \133\ Authors Alliance Comments, at 4.
                ---------------------------------------------------------------------------
                 While there was general support for this proposed change, several
                commenters noted the importance of implementing a corresponding method
                for authenticating or confirming the identity of registrants,
                assignees, or their authorized representatives. RIAA stated there must
                be ``robust security and authentication surrounding the authorized
                user's credentials and access to the registration database.'' \134\
                Likewise, the Copyright Alliance suggested that ``[t]he ability to make
                these changes should be restricted to accounts belonging to the rights
                holder (including a previous rights holder's verified successor in
                interest) or their agent'' to protect ``rights holders and users of the
                public record from fraud, misrepresentation, inadvertent mistakes and
                unauthorized changes to the record by third parties.'' \135\
                ---------------------------------------------------------------------------
                 \134\ RIAA Comments, at 6.
                 \135\ Copyright Alliance Comments, at 19.
                ---------------------------------------------------------------------------
                 In principle, the Office agrees that the ECS should be designed to
                encourage copyright owners to keep their contact information up to
                date, including in cases of transfer, and also that security and access
                controls will be key to implementing self-service edits.\136\ The
                [[Page 12713]]
                Office seeks additional stakeholder feedback on how the ECS might
                administer such a service. Specifically, what eligibility criteria
                should be considered in evaluating the parties seeking to edit Rights
                and Permissions information? Should this service be limited to users
                with access to the account through which the original registration was
                made, or should those users be able to consent or transfer account
                authorizations associated with individual registrations? Should this
                service be limited to parties named on the registration certificate and
                their authorized agents? The Office also seeks stakeholder feedback on
                whether to expand the Rights and Permissions field to allow users to
                provide more than one name and address. The Office will share this
                information with the OCIO to explore technological feasibility, and
                both the Office and the OCIO have committed to facilitating
                communication and outreach with users of the prospective system.
                ---------------------------------------------------------------------------
                 \136\ The option to edit Rights and Permissions information will
                not affect the recordation of documents pertaining to copyright.
                Rights and Permissions information is limited to contact information
                (e.g., mailing and/or email addresses).
                ---------------------------------------------------------------------------
                (B) Additional Data
                 The 2018 NOI invited comment on what additional data could or
                should be included in the online registration record on a voluntary
                basis in order to enhance the functionality and value of the
                system.\137\ The 2018 NOI noted that the current system already allows
                applicants to include a number of unique identifiers, including an
                International Standard Book Number (``ISBN''), International Standard
                Recording Code (``ISRC''), International Standard Serial Number
                (``ISSN''), International Standard Audiovisual Number (``ISAN''),
                International Standard Music Number (``ISMN''), International Standard
                Musical Work Code (``ISWC''), International Standard Text Code
                (``ISTC''), or Entertainment Identifier Registry number
                (``EIDR'').\138\ The 2018 NOI inquired whether the Office should
                consider expanding the number of unique identifiers that may be
                included on an application, requiring inclusion of unique identifiers
                if they have been assigned, or establishing a procedure for adding
                unique identifiers to completed registration records, similar to the
                proposed procedure for updating the Rights and Permission field.\139\
                ---------------------------------------------------------------------------
                 \137\ 83 FR at 52342.
                 \138\ Id.
                 \139\ Id.
                ---------------------------------------------------------------------------
                 Commenters were in favor of having the option to submit additional
                data as part of the registration application, as long as adding such
                information is not made mandatory.\140\ Commenters were also in favor
                of being able to provide unique identifiers to pending and completed
                registration records, on an optional basis.\141\ The Office agrees that
                any new requests for information should not be mandatory. Recognizing
                that certain standard identifiers may not always be available at the
                time of the registration application, the Office also appreciates the
                desire to add identifiers to the record after submission of a
                registration application, provided the online public record identifies
                when such amendments are made to completed registration records. The
                acceptance of post-registration unique identifiers would seem to
                potentially raise eligibility questions similarly presented with post-
                registration updates to the rights and permissions field, discussed
                above. Subject to additional public comment, the Office will work with
                the OCIO to explore the best ways to enable these types of voluntary
                submissions in the ECS.
                ---------------------------------------------------------------------------
                 \140\ See ABA-IPL Comments, at 6; AIPLA Comments, at 6; AAP
                Comments, at 7; AMI Comments, at 7; Copyright Alliance Comments, at
                20; Copyright Clearance Center, Inc. Comments, at 2 (Jan. 14, 2019);
                GAG Comments, at 8; INTA Comments, at 9; Shaftel & Schmelzer
                Comments, at 17 (Jan. 11, 2019).
                 \141\ See Copyright Alliance Comments, at 20; INTA Comments, at
                9; MPAA Comments, at 10.
                ---------------------------------------------------------------------------
                 In addition, the Office sought comment on whether it should allow
                applicants to voluntarily upload public-facing deposit material, such
                as low-resolution images or sound bites, as part of the registration
                application.\142\ The option to include this information would be
                additive of the existing registration deposit requirement. Such public-
                facing material might assist in the identification of a work to serve
                licensing, or even enforcement, purposes. Commenters generally were
                supportive of this proposal. INTA opined that ``developing a more
                robust Online Public Record through the uploading of these images and
                clips will be beneficial by enhancing recognition of the work
                registered and will also aid in the licensing of those works.'' \143\
                NMPA observed that ``[a]llowing applicants to include small sound bites
                of their works in their application could improve the public record and
                assist the public in identifying copyright owners.'' \144\ Public
                Knowledge (``PK'') and the Association of Real Estate Photographers
                (``AREP'') suggested that ``[i]mplementing reverse image search
                capabilities . . . --and linking those results to rightsholder
                information--would prov[ide] significant benefits for both users and
                rightsholders.'' \145\ Noting that ``[t[he technology to search by
                images . . . is widely commercially available,'' PK and AREP stated
                that the ability to ``reverse image search existing registrations would
                assist photographers . . . in protecting their rights online.'' \146\
                ---------------------------------------------------------------------------
                 \142\ 83 FR at 52342.
                 \143\ INTA Comments, at 9-10.
                 \144\ NMPA Comments, at 15.
                 \145\ PK & AREP Comments, at 3 (Jan. 15, 2019).
                 \146\ Id.
                ---------------------------------------------------------------------------
                 Other commenters, however, noted that there may be complications in
                accepting low-resolution or incomplete deposits. Specifically, RIAA
                argued that collecting sound clips ``would create additional burdens
                (including, but not limited to, the need to provide ever expanding
                storage resources for clips) on the Office with, at best, marginal
                increased utility.'' \147\ It also expressed concern that ``the
                collection and inclusion of sound clips in the Office's registration
                database could turn the database into a de facto, on-demand streaming
                service that would effectively compete against commercial services
                licensed by our member companies.'' \148\
                ---------------------------------------------------------------------------
                 \147\ RIAA Comments, at 6-7.
                 \148\ Id. at 7.
                ---------------------------------------------------------------------------
                 Still others discussed the availability of technology to create
                low-resolution or incomplete copies. For example, ImageRights suggested
                that there would be ``little point in asking users to provide'' low-
                resolution images and sound bites because they ``can be created
                sufficiently well in an automated way.'' \149\ GiantSteps Media
                Technology Strategies suggested that the Office use digital finger
                printing technology to ``allow registrants to deposit digital
                fingerprints of works, perhaps in addition to low-resolution images,
                audio clips, and the like.'' \150\
                ---------------------------------------------------------------------------
                 \149\ ImageRights Comments, at 8.
                 \150\ GiantSteps Media Technology Strategies Comments, at 3
                (Jan. 15, 2019).
                ---------------------------------------------------------------------------
                 To more fully explore these issues, the Office is interested in
                receiving additional input on whether and how the new ECS might be
                designed to include the option to deposit low-resolution or incomplete
                copies of works for the online public record. Are there certain
                available technologies that should be considered to automate creation
                of lower-resolution or shortened clips works to be made available to
                the public for identification purposes but that would not serve as a
                substitute for the work? Should the Office establish specifications,
                such as a 15-second limit on sound clips, or a specific resolution
                format, with respect to the acceptance of additional, voluntarily
                submitted data, to minimize interactions with licensing markets? Should
                this feature be preliminarily
                [[Page 12714]]
                explored in a pilot limited to certain type(s) of works, and if so,
                which type(s)?
                 The Office invites comment on any additional considerations it
                should take into account relating to these topics.
                 Dated: February 28, 2020.
                Regan A. Smith,
                General Counsel and Associate Register of Copyrights.
                [FR Doc. 2020-04435 Filed 3-2-20; 8:45 am]
                 BILLING CODE 1410-30-P
                

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