Section 1201 Exemptions to Prohibition Against Circumvention of Technological Measures Protecting Copyrighted Works: Comments

Comments in response to the December 12, 2014 Notice of Proposed rulemaking were due on February 6, 2015.

Note: A participant in this proceeding (Free Software Foundation) erroneously submitted its comments through the Regulations.gov website (operated by the Federal Register), rather than through the Copyright Office website as the Notice of Proposed Rulemaking had instructed. This error led to a substantial delay before the Copyright Office received these comments. In light of the Federal Register’s inadvertent acceptance of those comments, the Office is posting them below notwithstanding the error, and is working with the Federal Register to address this concern for the future. In the meantime, participants are reminded to submit comments as instructed by the Copyright Office via the Office’s website, at http://www.copyright.gov/1201 (not through Regulations.gov).


Class Commenter
 

GENERAL COMMENTS

 

Digital Age Defense project

New America’s Open Technology Institute

Owners’ Rights Initiative

Public Knowledge

1

Proposed Class 1: Audiovisual works – educational uses – colleges and universities


Joint Educators

Music Library Association

Sheff, Jeremy N.

Combined comments (1501) received through Digital Right to Repair website

Free Software Foundation

2

Proposed Class 2: Audiovisual works – educational uses – primary and secondary schools (K-12)

 

Hobbs, Renee

Music Library Association

Free Software Foundation

3

Proposed Class 3: Audiovisual works – educational uses – massive open online courses (“MOOCs”)

 

Joint Educators

Music Library Association

Free Software Foundation

4

Proposed Class 4: Audiovisual works – educational uses – educational programs operated by museums, libraries, or nonprofits

 

Hobbs, Renee

Music Library Association

Free Software Foundation

5

Proposed Class 5: Audiovisual works – derivative uses – multimedia e-books

 

Author’s Alliance, et al.

Music Library Association

Combined comments (1408) received through Digital Right to Repair website

Free Software Foundation

6

Proposed Class 6: Audiovisual works – derivative uses – filmmaking uses

 

Joint Filmakers

New Media Rights

Combined comments (1565) received through Digital Right to Repair website

Free Software Foundation

7

Proposed Class 7: Audiovisual works – derivative uses – noncommercial remix videos

 

Electronic Frontier Foundation and Organization for Transformative Works -

(multimedia submissions)

Music Library Association

National Congress of American Indians

New Media Rights

USC Norman Lear Center

Combined comments (1574) received through Digital Right to Repair website

Free Software Foundation

8

Proposed Class 8: Audiovisual works – space-shifting and format-shifting

 

Music Library Association

Public Knowledge

Free Software Foundation

9

Proposed Class 9: Literary works distributed electronically – assistive technologies

 

Association of American Publishers

American Foundation for the Blind et al.

iFixit

Music Library Association

Combined comments (1292) received through Digital Right to Repair website

Free Software Foundation

10

Proposed Class 10: Literary works distributed electronically – space-shifting and format-shifting

 

Englander, Rachel

Music Library Association

Free Software Foundation

11

Proposed Class 11: Unlocking – wireless telephone handsets

 

Competitive Carriers Association

Consumers Union

eBay Inc. and Gazelle

iFixit

Institute of Scrap Recycling Industries, Inc.

Rosario, Mervin

Combined comments (2304) received through Digital Right to Repair website

Free Software Foundation

12

Proposed Class 12: Unlocking – all-purpose tablet

 

Competitive Carriers Association

Consumers Union

iFixit

Institute of Scrap Recycling Industries, Inc.

Combined comments (2309) received through Digital Right to Repair website

Free Software Foundation

13

Proposed Class 13: Unlocking – mobile connectivity devices

 

Competitive Carriers Association

SAE International, Vehicle Electrical System Security Committee

Combined comments (1895) received through Digital Right to Repair website

Free Software Foundation

14

Proposed Class 14: Unlocking – wearable computing devices

 

Competitive Carriers Association

Combined comments (1632) received through Digital Right to Repair website

Free Software Foundation

15

Proposed Class 15: Unlocking – consumer machines

 

Competitive Carriers Association

iFixit

Combined comments (1589) received through Digital Right to Repair website

Free Software Foundation

16

Proposed Class 16: Jailbreaking – wireless telephone handsets

 

Blinky X

Cantarero, Eli

Darling, David

de Kroon, Andrew

Electronic Frontier Foundation -

(multimedia submissions)

Freeman, Jay

Marquez, Anthony

Moschell, Kyle

New Media Rights

Roddy, Jeffrey Philip

Ross, Micah

Ross, Robert

SAE International, Vehicle Electrical System Security Committee

Vahrenberg, Nathan

Winget Jr., Edward

Wong, AK

Combined comments (2087) received through Digital Right to Repair website

Free Software Foundation

17

Proposed Class 17: Jailbreaking – all-purpose mobile computing devices

 

de Kroon, Andrew

Deriso, George G.

Electronic Frontier Foundation -

(multimedia submissions)

Freeman, Jay

Garver, David

Moschell, Kyle

New Media Rights

Ross, Robert

SAE International, Vehicle Electrical System Security Committee

Scandella, Nathan

Wong, AK

Combined comments (1884) received through Digital Right to Repair website

Free Software Foundation

18

Proposed Class 18: Jailbreaking – dedicated e-book readers

 

Freeman, Jay

Combined comments (1608) received through Digital Right to Repair website

Free Software Foundation

19

Proposed Class 19: Jailbreaking – video game consoles

 

iFixit

Combined comments (1647) received through Digital Right to Repair website

Free Software Foundation

20

Proposed Class 20: Jailbreaking – smart TVs

 

Exploiteers

Freeman, Jay

Software Freedom Conservancy

Combined comments (1724) received through Digital Right to Repair website

Free Software Foundation

21

Proposed Class 21: Vehicle software – diagnosis, repair, or modification

 

Electronic Frontier Foundation

Farm Hack

Freeman, Jay

Intellectual Property & Technology Law Clinic, University of Southern California - (multimedia submissions)

Rogers, Scott

SAE International Dedicated Short Range Communication Standards Committee

iFixit & Kyle Wiens

iFixit

Combined comments (2284) received through Digital Right to Repair website

Free Software Foundation

22

Proposed Class 22: Vehicle software – security and safety research

 

Electronic Frontier Foundation

Green, Matthew D.

SAE International, Dedicated Short Range Communication Standards Committee

SAE International, Vehicle Electrical System Security Committee

Combined comments (1816) received through Digital Right to Repair website

Free Software Foundation

23

Proposed Class 23: Abandoned software – video games requiring server communication

 

Battilana, Mike

Electronic Frontier Foundation

Combined comments (1145) received through Digital Right to Repair website

Free Software Foundation

24

Proposed Class 24: Abandoned software – music recording software

 

Battilana, Mike

Music Library Association

Combined comments (1530) received through Digital Right to Repair website

Free Software Foundation

25

Proposed Class 25: Software – security research

 

Andersen, Gavin, et al.

Brown, Ian, et al.

Green, Matthew

Internet Association

Radcliffe, Jay

Rice, Brian M.

SAE International, Vehicle Electrical System Security Committee

Bellovin et al.

Center for Democracy & Technology

Stanislav, Mark

Stolfo, Salvatore J.

USACM

Verified Voting Foundation

Combined comments (1546) received through Digital Right to Repair website

Free Software Foundation

26

Proposed Class 26: Software – 3D printers

 

Public Knowledge and Library Copyright Alliance

Combined comments (1577) received through Digital Right to Repair website

Free Software Foundation

27

Proposed Class 27: Software – networked medical devices

 

Coalition of Medical Device Researchers

Freeman, Jay

Green, Matthew

Public Knowledge

Combined comments (1659) received through Digital Right to Repair website

Free Software Foundation