AIPLA Comments Submitted Pursuant to "Notice of Proposed Rulemaking on Copyright Office Fees," 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.

Of course, it is not possible to know with certainty how the proposed increases would impact a copyright owner’s willingness to utilize the Office’s services. Further, the Office has undertaken various initiatives in recent years, and intends to introduce others, that may increase the use and usability of its services.

For these reasons, AIPLA has framed its comments below by identifying certain overarching questions or concerns from AIPLA’s review of the proposed fee increases, followed by various items to consider with regard to the proposed increases for specific fee categories. In some instances, it may be appropriate for the Copyright Office to monitor the actual effect of any higher fees after implementation to determine if the effects comport with the Office’s stated expectations and goals.