DMCA comments to the Library of Congress about prohibition against circumvention

Posted 30 Oct 2002 at 02:22 UTC by aicra Share This

It's almost time to write DMCA comments to the LOC!

For those interested in sending the Library of Congress written comments about prohibition against circumvention of technical measures...(1201) HERE IS OUR CHANCE!

Wouldn't it be great if they received THOUSANDS of comments...:) Or at least a few great ones!

Here is more information at


Written comments submissions begin Nov. 19 and are due to the LOC by December 18!

The copyright office is taking comments about DMCA and the prohibition against circumvention. Written comments are due by December 18.

There is a 19 page notice of inquiry at the above URL in pdf format. This inquiry goes into detail about the scope of the DMCA comments and the requirements for submission.


Examples of comments made in the past are available at: and


"The Copyright Office is preparing to conduct proceedings mandated by the Digital Millennium Copyright Act, which provides that the Librarian of Congress may exempt certain classes of works from the prohibition against circumvention of technological measures that control access to copyrighted works. The purpose of this rulemaking proceeding is to determine whether there are particular classes of works as to which users are, or are likely to be, adversely affected in their ability to make noninfringing uses due to the prohibition on circumvention.

WHO can submit? Everyone. The DMCA affects us all!
This notice requests written comments from all interested parties, including representatives of copyright owners, educational institutions, libraries and archives, scholars, researchers and members of the public, in order to elicit evidence on whether noninfringing uses of certain classes of works are, or are likely to be, adversely affected by this prohibition on the circumvention of measures that control access to copyrighted works.

Electronic submissions may be made through this website beginning Nov. 19, 2002, through Dec. 18. For more information, please see the notice of inquiry."

How to make submissions
"The Copyright Office's website will contain a submission page at: . Approximately thirty days prior to each applicable deadline..., a form will be activated on the Copyright Office website allowing information to be entered into the required fields, including the name of the person making the submission, his or her title, organization, mailing address, telephone number, and email address.

For initial comments, there will be two additional fields required: 1) the proposed class or classes of copyrighted work(s) to be exempted, and 2) a brief summary of the argument(s).

The comment or reply comment itself must be sent as an attachment, and must be in a single file in either Adobe Portable Document File (PDF) format (preferred), in Microsoft Word Version 2000 or earlier, or in WordPerfect 9 or earlier, or in ASCII text.

Petition, posted 30 Oct 2002 at 11:43 UTC by chalst » (Master)

One well-worded petition, with 1000 moderately trustworthy signatures, would be more effective than a thousand emails. Perhaps talking about what to say in it (I suggest contacting Lawrence Lessig), and figuring out a reasonable signature verification scheme (eg. adding a petition signing capability to an advogato user account), would be a good way for respondents to this article to proceed.

petition, posted 31 Oct 2002 at 00:53 UTC by aicra » (Journeyer)

I know that Chris Dibona had a petition on his site


Bryan Taylor from Openlaw was proactive enough to word a nice petition online

with over 10,000 signatories.

The petitions are a good idea, but I'm not sure Lessig has the time or the technical qualifications to draft this type of petition... I mean, he must be a busy man. He did take time to speak at the Dmitry thing last August, but the next day, he didn't have time to protest with RMS, Perens, et al in San Fran.

Maybe there is some way we can use Dibona and Taylor's petitions.


Re: petition, posted 1 Nov 2002 at 13:36 UTC by chalst » (Master)

Two points: firstly, I was not suggesting we ask Lessig to *draft* a petition, but he may provide feedback on how to make an existing draft more persuasive to various readers.

Second, the advantage of making use of the advogato account system is that the trust-metric can provide a fairly good assurance that almost all signatures are valid. I wouldn't put much confidence in the number of signatures for either of the petitions you cite.

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