Copyright Office
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AIPLA Submits Comments to US Copyright Office Regarding Deferred Registration Examination Study
January 24, 2022
On January 24, 2022, the American Intellectual Property Law Association (AIPLA) submitted comments to the United States Copyright Office pursuant to the Notice of Inquiry related to the deferred registration examination study. The comments address perceived deficiencies in the current registration regime, benefits and drawbacks to offering a deferred examination option, legal or regulatory framework, filing fees, and more. -
AIPLA Submits Comments to U.S. Copyright Office Pursuant to Notice of Proposed Rulemaking Related to CASE Act Regulations
November 10, 2021
On November 10, 2021, AIPLA submitted comments to the U.S. Copyright Office pursuant to the Notice of Proposed Rulemaking (NPRM) related to CASE Act regulations. Comments provided included support for requiring claimants to provide contact information in the initial notice form and support for charging filing fees for counterclaims. A staggered fee structure was again suggested, and support was provided for an initial notice in a form that includes information required by the statute and additional basic information. An opt-out mechanism for claimants who receive a counterclaim was not supported, and concern was expressed regarding implementation of a mechanism whereby a respondent who has opted out of a CCB proceeding can change their mind and opt back in.
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AIPLA Submits Comments on Notification of Inquiry Regarding Copyright Alternative in Small-Claims Enforcement (“CASE”) Act Regulations
April 26, 2021
On April 26, 2021, AIPLA submitted comments to the U.S. Copyright Office on Notification of Inquiry regarding Copyright Alternative in Small-Claims Enforcement (“CASE”) Act Regulations. As a general matter, AIPLA believes that it is important to keep the procedures as straight forward and accessible as possible to ensure this will be a new, simple, and low-cost process to resolve small copyright claims. AIPLA encourages the Copyright Claims Board to publish standardized forms and instructions. Additionally, AIPLA is in favor of providing a Second Notice through the U.S. Postal Service. For ease of delivery, AIPLA is in favor of a Designated Agent directory. Online submission of opt-out notices should be encouraged, but a paper option is also recommended. To strike an appropriate balance of discovery, AIPLA recommends that the CCB require a standardized, initial disclosure of relevant information. -
Comments Submitted Pursuant to Sovereign Immunity Study: Notice and Request for Public Comment, 85 Fed. Reg. 34,252
September 2, 2020
AIPLA's comments in response to the above-referenced U.S. Copyright Office Notice and Request for Public Comment, in the wake of the U.S. Supreme Court’s ruling in Allen v. Cooper, 140 S.Ct. 994 -
Comments to Copyright Office on Registration Modernization
June 1, 2020
AIPLA supports and appreciates the Copyright Office’s efforts to modernize the copyright registration system. -
Recommendations on the Position of Register of Copyrights
March 23, 2020
AIPLA discusses the traits the association views as essential for the position of Register of Copyrights. -
Comments to Copyright Office Pursuant to Notification of Inquiry Regarding Online Publication
March 23, 2020
In AIPLA’s view, issues and confusion regarding “online” publication arise from the statute itself. If such issues are to be resolved, we believe that this is best done by Congress. -
Re: Comments Submitted Pursuant to “Notification of Inquiry,” 83 Fed. Reg. 52336 (Oct. 17, 2018)
October 17, 2018
The American Intellectual Property Law Association (AIPLA) is pleased to offer comments in response to the United States Copyright Office (the “Office”) Notification of Inquiry, 83 Fed. Reg. 52336, issued October 17, 2018, concerning various proposed efforts to modernize the registration process (NOI). -
AIPLA Comments Submitted Pursuant to "Notice of Proposed Rulemaking on Copyright Office Fees," September 21, 2018
September 21, 2018
While AIPLA recognizes the Copyright Office’s right and need to increase its fees periodically—and further recognizes that any proposed fee increase will ordinarily be met with some degree of reluctance by those incurring the increased expense—some of the Office’s proposed fee increases here raise certain questions and concerns for AIPLA members that we would like to bring to your attention. -
AIPLA Comments Submitted Pursuant to Request for Additional Comments Regarding Section 512 Study
February 21, 2017
Although the mechanisms of Section 512 are used now more than ever, many stakeholders believe the system can be improved substantially, and in a variety of ways that reflect the “great diversity among the categories of content creators and ISPs who comprise the Internet ecosystem.” -
AIPLA Comments on IT Modernization Plan
March 31, 2016
AIPLA supports funding the Copyright Office’s modernization efforts, including the goals reflected in the IT Plan, through a blend of fees for services and dedicated appropriated dollars. -
Comments Submitted Pursuant to Request for Comments Regarding “Mass Digitization Pilot Program,”
October 9, 2015
The American Intellectual Property Law Association (“AIPLA”) is pleased to have the opportunity to present its views on the above-referenced U.S. Copyright Office request for comments regarding “Mass Digitization Pilot Program,” 80 Fed. Reg. 32614 (June 9, 2015). -
AIPLA Comments Submitted Pursuant to Notice of Inquiry Regarding "Copyright Protection for Certain Visual Works,"
July 23, 2015
AIPLA believes the ease of unauthorized copying online is a major challenge to the licensing of visual works. -
AIPLA Comments Submitted Pursuant to Notices of Inquiry Entitled “Orphan Works and Mass Digitization; Request for Additional Comments and Announcement of Public Roundtables,”
May 21, 2014
The American Intellectual Property Law Association (AIPLA) is pleased to submit these comments in response the above-referenced Notices of Inquiry concerning the Office’s ongoing assessment of orphan works and mass digitization. -
AIPLA Comments on Notice of Inquiry Regarding "Technological Upgrades to Registration and Recordation Functions"
May 20, 2013
The American Intellectual Property Law Association (AIPLA) is pleased to offer the following comments concerning the U.S. Copyright Office Notice of Inquiry regarding “Technological Upgrades to Registration and Recordation Functions” published in the March 22, 2013, issue of the Federal Register, 78 Fed. Reg. 17722. -
AIPLA Comments Submitted Pursuant to Notice of Inquiry Regarding "Orphan Works and Mass Digitization"
February 4, 2013
The American Intellectual Property Law Association (AIPLA) is pleased to offer comments in response to the U.S. Copyright Office Notice of Inquiry entitled “Orphan Works and Mass Digitization” (the “NOI”), as published in the October 22, 2012 issue of the Federal Register. 77 Fed. Reg. 64555. -
AIPLA Comments on Remedies for Small Copyright Claims
January 16, 2012
AIPLA applauds efforts by Congress and the Copyright Office to ensure that copyright owners of all kinds–large and small–have the ability to effectively protect their rights in their works. -
AIPLA Comments to DMCA Rulemaking Regarding Exemptions to Prohibition on Circumvention of Copyright Protection Systems for Access Control Technologies
February 2, 2009
AIPLA agrees that, for certain classes of work, exemptions to the Digital Millennium Copyright Act's ("DMCA") anti-circumvention provisions are warranted. -
Comments Submitted Pursuant to Notice of Inquiry to Examine Issues Raised by “Orphan Works”
May 8, 2005
AIPLA agrees that difficulties in identifying and locating the owners of copyright in some “orphan works” present a genuine problem, and that society would benefit from greater access to such works.
Recent Advocacy
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AIPLA Files Amicus Brief with the Court of Appeals for the Federal Circuit in Google LLC v. Sonos, Inc.
March 21, 2024
Arlington, VA. February 29, 2024 - The American Intellectual Property Law Association (AIPLA) filed an amicus brief in support of neither party with the Court of Appeals for the Federal Circuit in Google LLC v. Sonos, Inc., a case on appeal from the U.S. District Court for the Northern District of California. The district court held that the post-GATT patents-in-suit are unenforceable under the doctrine of prosecution laches and found unreasonable and inexcusable delay where 13 years had elapsed between the provisional patent application and presenting the claims at issue. -
AIPLA Comments to Copyright Office on Group Registration of Updates to a News Website
February 22, 2024
Arlington, VA. February 20, 2024 - The American Intellectual Property Law Association (AIPLA) submitted comments in response to the U.S. Copyright Office's Notice of Proposed Rulemaking related to group registration of updates to a news website. -
AIPLA Comments to HHS on WHO Pandemic Treaty
February 8, 2024
Arlington, VA. January 31, 2024 - The American Intellectual Property Law Association (AIPLA) submitted comments in response to the RFC on Implications of Access and Benefit Sharing (ABS) Commitments/Regimes and Other Proposed Commitments in the World Health Organization (WHO) Pandemic Agreement.
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AIPLA Comments to USPTO on Rules of Practice To Allocate the Burden of Persuasion on Motions To Amend in Trial Proceedings Before the Patent Trial and Appeal Board
December 23, 2019
AIPLA appreciates the Office’s efforts to improve AIA trial proceedings, which have become pervasive since their initial implementation in September 2012. -
AIPLA Submits Amicus Brief to PTAB in Hunting Titan, Inc. v. Dynaenergetics & Co. Kg
December 20, 2019
The Patent Trial and Appeal Board should make any determination of unpatentability based on the arguments and evidence of record. -
AIPLA-IPO Joint Letter to Senate Judiciary Committee in Support of Counterfeit Goods Seizure Act
December 9, 2019
The American Intellectual Property Law Association submitted a letter to the Senate Judiciary Committee in support of the Counterfeit Goods Seizure Act of 2019. -
AIPLA Comments to USPTO on Patent Term Adjustment Reductions in View of the Federal Circuit Decision in Supernus Pharm., Inc. v. Iancu
December 3, 2019
AIPLA agrees that that many of the Office’s proposed revisions to 37 CFR §§ 1.704(c)(1) through (c)(14) are consistent with the requirement set forth in the Supernus decision that a reduction in patent term adjustment correspond to “the period from the beginning to the end of the applicant’s failure to engage in reasonable efforts to conclude prosecution.” -
AIPLA Comments to TTAB Regarding Issuance of Precedential Decisions by the Trademark Trial and Appeal Board
November 20, 2019
AIPLA believes that an increased number of precedential TTAB decisions would be helpful to trademark owners, trademark practitioners, educators, and students. -
Comments to CBP Regarding Its Proposal to Amend US Customs and Border Protection Regulations Pertaining to Disclosure of Information Regarding Abandoned Merchandise
November 15, 2019
The American Intellectual Property Law Association submitted a letter to US Customs and Border Protection (CBP) to present its views with respect to the Notice of Proposed Rulemaking to Amend U.S. Customs and Border Protection Regulations Pertaining to Disclosure of Information Regarding Abandoned Merchandise 19 CFR Parts 127 and 133 dated August 27 2019 (the NPRM). -
AIPLA Comments to USPTO on Patenting Artificial Intelligence Inventions
November 8, 2019
AIPLA proposes adopting the distinguishing terms “inventive AI” and “AI inventions.” -
AIPLA Comments to USPTO on Annual Patent Practitioner Fee Proposal
November 8, 2019
AIPLA believes the proposal for an annual patent practitioner fee, if implemented, would fundamentally change the relationship between the Office, the practitioners and the applicants.