U.S. Copyright Office - Reply Comments on Rulemaking on Anticircumvention: Page 1

Reply Comments on Rulemaking on Anticircumvention

This page contains reply comments submitted as a part of a rulemaking on exemptions from prohibition on circumvention of technological measures that control access to copyrighted works (read more details). The following comments were submitted in the first round of comments between Nov. 19 and Dec. 18, 2002.

This is page one of nine pages of reply comments, which can be accessed through the links below.

Page 1 | Page 2 | Page 3 | Page 4 | Page 5 | Page 6 | Page 7 | Page 8 | Page 9 | Page 10 | Page 11

Note: In order to view the PDF files below, your computer must be equipped with the free Adobe Acrobat Reader 6 program or other software capable of reading PDF version 1.4 files.

1		Steven Mitchell
Replying to Comment		36
Class of Works		Audiovisual works as follows: foreign-language audiovisual works not available for sale in the United States but available for purchase outside the US on DVDs that are regionally encoded to prevent playback on DVD players purchased in the United States. The exemption requested is to permit circumvention of the region coding mechanism.
		Reply comment (1 page)

2		Brian Takle
Replying to Comment		2
Class of Works		Literary works, including computer programs and databases, protected by access control mechanisms in which the mechanism controls access both to copyrighted works and to works not under copyright.
		Reply comment (1 page)

3		Michael Peters
Replying to Comment		7
Class of Works		All classes of copyrighted works should be exempted under certain conditions.
		Reply comment (1 page)

4		Michael A. Rolenz
Replying to Comment		14
Class of Works		Information collected by "Spyware" software that is encrypted or "Spyware" software whose operation uses encryption to hide its operation.
		Reply comment (2 pages)

5		Michael A. Rolenz
Replying to Comment		40
Class of Works		Literary works, including computer programs and databases, protected by access control mechanisms that fail to permit access to recognize shortcomings in security systems, to defend patents and copyrights, to discover and fix dangerous bugs in code, or to conduct forms of desired educational activities.
		Reply comment (1 page)

6		Michael A. Rolenz
Replying to Comment		24
Class of Works		Data archival mechanisms
		Reply comment (1 page)

7		June M. Besek
Replying to Comment		2, 14, 20, 25, 29, 30, 31, 32, 33, 34, 35
Class of Works		A. Compilations consisting of lists of websites blocked by filtering software applications; and literary works, including computer programs and databases, protected by access control mechanisms that fail to permit access because of malfunction, damage or obsoleteness; B. Audiovisual works that are in the public domain in the United States and that are released solely on DVDs, access to which is prevented by technological protection measures; C. Literary and audiovisual works embodied in software whose access control systems prohibit access to replicas of the works; D. Sound recordings released on compact disc (‘CDs’) that are protected by technological protection measures that malfunction so as to prevent playback on certain playback devices; and E. Copyrighted works protected by access controls that limit their use to a particular machine or platform.
		Reply comment (9 pages)

8		Michael A. Rolenz
Replying to Comment		23
Class of Works		Data file formats, including but not limited to word processing-, image- and music file types.
		Reply comment (2 pages)

9		David B. Carroll
Replying to Comment		36
Class of Works		Audiovisual works as follows: foreign-language audiovisual works not available for sale in the United States but available for purchase outside the US on DVDs that are regionally encoded to prevent playback on DVD players purchased in the United States.
		Reply comment (30 pages)

10		Jeff Clark Consortium of College & University Media Centers
Replying to Comment		2, 5, 33
Class of Works		I. Literary works, including computer programs and databases, protected by access control mechanisms that fail to permit access because of malfunction, damage, or obsoleteness. II. Compilations consisting of lists of websites blocked by filtering software applications. III. Literary works, including eBooks, which are protected by technological measures that fail to permit access, via a 'screen reader' or similar text-to-speech or text-to-braille device, by an otherwise authorized person with a visual or print disability. IV. Literary works, including computer programs and databases, protected by access control mechanisms in which the mechanism controls access both to copyrighted works and to works not under copyright. V. Any digital-format work, including but not limited to Compact Discs (CDs) and Digital Versatile Discs (DVDs) which contain material not available in a comparable analog format at a price no more than ten percent (10%) higher than the cost of the digital work.
		Reply comment (4 pages)

11		David Burt N2H2
Replying to Comment		29, 31, 32, 33
Class of Works		Compilations consisting of lists of websites blocked by filtering software applications.
		Reply comment (44 pages)

12		Shawn Hernan CERT/CC
Replying to Comment		32, 40
Class of Works		Literary works, including computer programs and databases, protected by access control mechanisms that fail to permit access to recognize shortcomings in security systems, to defend patents and copyrights, to discover and fix dangerous bugs in code, or to conduct forms of desired educational activities. Literary works, including computer programs and databases, protected by access control mechanisms that are at high risk of failure in the near-term future because of malfunction, damage or obsoleteness. Literary works, including computer programs and databases, protected by access control mechanisms that fail to permit access because of the copyright owner and/or their designated agent fail to provide the necessary support means.
		Reply comment (7 pages)

13		Adriel T. Desautels Secure Network Operations, Inc.
Replying to Comment		7
Class of Works		All classes of copyrighted works should be exempted under certain conditions.
		Reply comment (2 pages)

14		Matthew Perkins
Replying to Comment		5, 10, 15, 20, 21, 28
Class of Works		Audiovisual works on DVD protected by the Content Scrambling System; Ancillary audiovisual works distributed on Digital Versatile Discs (DVDs) using the Content Scrambling System; etc.
		Reply comment (15 pages)

15		Simon Carless and Brewster Kahle Internet Archive
Replying to Comment		29, 32, 33
Class of Works		Literary works, including computer programs and databases, protected by access control mechanisms that fail to permit access because of malfunction, damage or obsoleteness.
		Reply comment (7 pages)

16		Ken Arromdee
Replying to Comment		16, 35
Class of Works		Class #1: Audiovisual works stored on DVDs that are not available in Region 1 DVD format and access to which is prevented by technological measures. Class #2: Audiovisual works released on DVD that contain access control measures that interfere with the ability to control private performance, including the ability to skip promotional materials. Class #3: Tools which existed before and happen to be able to circumvent newer products' access controls.
		Reply comment (3 pages)

17		Ryland Hawkins
Replying to Comment		2, 8, 14, 20
Class of Works		Literary works, Ebooks, Works in the Public Domain
		Reply comment (2 pages)

18		Riley R. Russell Sony Computer Entertainment America Inc.
Replying to Comment		15, 32
Class of Works		1. “Software and games that are played on video game machines” as raised in Submission Number 15; and to the proposal to exempt, 2. “Literary works (including computer software and databases, musical works and motion picture works which are region coded, and for which the nearly identical product except for being keyed for a region containing the United States does not exist for mass-market consumption within the United States,” as raised in Submission Number 32 item (6).
		Reply comment (5 pages)

19		Shira Perlmutter AOL Time Warner
Replying to Comment		1, 5, 6, 8, 9, 10, 11, 13, 15, 17, 20, 21, 30, 32, 34, 35, 36, 39, 42
Class of Works		Works for which those filing comments seek exemptions limiting a copyright owner’s ability to control conditions of access to the work once a consumer has obtained initial lawful access or purchased a physical copy, including: (1) works for which those filing comments seek exemptions to allow the work to be used on platforms other than those designed for the format in which the consumer chose to purchase the work; (2) works for which those filing comments seek exemptions to allow circumvention in order to gain access to bonus content available only in a particular format or to circumvent regional coding.
		Reply comment (11 pages)

20		Douglas Lowenstein Interactive Digital Software Association
Replying to Comment		15, 32
Class of Works		1) Software and games that are played on video game machines (Submission 15) 2) Literary works (including computer software and databases), musical works, and motion picture works which are region coded, and for which the nearly identical product except for being keyed for a region containing the United States does not exist for mass-market consumption within the United States (Submission 32(6))
		Reply comment (9 pages)

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