Thursday, June 22, 2017

Copyright Office issues 1201 report

Available here.  It's a lot to go through, but on first inspection they seem to be trying to address persistent problems, though in the main not by accepting the advice that participants had for them (like scheduling 1201 exemption proposals in a way that makes sense for law school clinics, and performing administrative factfinding rather than treating this as an adversarial procedure where the Office's role is to adjudicate).  One immediate thought: even if the goal of making it possible to participate in the rulemaking without counsel were achieved, that won't help if the exemptions continue to get ever more complex, so that you need counsel to use them.

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