Additional Comments on DMCA Section 1201 Reform

CDT has submitted additional comments on the the Copyright Office policy study focused on Section 1201 of the Digital Millennium Copyright Act (DMCA), which prohibits the circumvention of technological protection measures (TPMs). CDT commented in the initial phase of this study, and these comments address the Office’s response to the proposals received to update the statute. CDT is pleased that the Copyright Office is taking a hard look at Section 1201 and hopes to see positive changes result from this policy study. However, we were disappointed to see that the study has become focused solely on legislative changes and that the Office’s proposals only address the permanent statutory exemptions, but not the temporary exemption rulemaking process.