AIPLA Comments to Copyright Office on Group Registration of Two-Dimensional Artwork

Written April 2, 2024

Arlington, VA. April 1, 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 two-dimensional artwork.

AIPLA commends the Office for expanding group registration options and increasing accessibility to the registration system for individual creators but offers suggestions for improvement. The comments note that the proposal does not include three-dimensional (3D) works due to longer design times and fewer productions within the proposed 30-day publication window. However, it highlights the increasing accessibility of 3D printing technology to the public, suggesting a potential expansion to include 3D works in the future. Additionally, the comments express concerns about the possibility that unilateral registration decisions made by the Office without coordination with applicants could inadvertently prejudice applicants' rights under the Copyright Act. It recommends communication with applicants to address mistakes or ambiguity in the application to allow applicants to make strategic decisions on which works to register. The comments acknowledge that the regulations must take into consideration technical limitations in the Office's electronic registration systems, and urges the Office to be proactive in revisiting the regulations in the future as these limitations are overcome by the Office’s next-generation technological framework.


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