December 20, 2002

DMCA exemption comments - a second bite at the apple

The first round of DMCA comments is done. But if people want to submit DMCA exemptions material to the Copyright Office, there's a second chance.

The 2002 notice of inquiry says (my emphasis):

In the reply comments, persons who oppose or support any exemptions proposed in the initial comments will have the opportunity to respond to the proposals made in the initial comments and to provide factual information and legal argument addressing whether a proposed exemption should be adopted. Since the reply comments are intended to be responsive to the initial comments, reply commenters must identify what proposed class they are responding to, whether in opposition, support, amplification or correction. As with initial comments, reply comments should first identify the proposed class, provide a summary of the argument, and then provide the factual and/ or legal support for their argument. This format of class/ summary/ facts and/ or legal argument should be repeated for each reply to a particular class of work proposed.


Reply comments will be accepted from January 21, 2003, until February 19, 2003, at 5:00 P. M. Eastern Standard Time.

So there's another opportunity very soon.

Update: Note this is an even better opportunity then the first round. The 2002 rulemaking page says (my emphasis):

The initial round of comments (due December 18, 2002) is restricted to comments proposing exemptions for specific classes of works. Reply comments (due February 19) may be submitted in opposition to or in further support of exemptions proposed in the initial comments.

So you can file support comments for other comments. In fact, people can even make a reply comment in further support of their own initial comment!

By Seth Finkelstein | posted in dmca | on December 20, 2002 10:07 AM (Infothought permalink) | Followups

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