Remedies for Small Copyright Claims, 66758-66761 [2011-27824]
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Federal Register / Vol. 76, No. 208 / Thursday, October 27, 2011 / Notices
investigation in these cases would serve
no purpose since the petitioning group
of workers cannot be covered by more
than one certification at a time.
TA–W–80,427; Coastal Lumber
Company, Hopwood, PA
I hereby certify that the
aforementioned determinations were
issued during the period of October 11,
2011 through October 14, 2011. Copies
of these determinations may be
requested under the Freedom of
Information Act. Requests may be
submitted by fax, courier services, or
mail to FOIA Disclosure Officer, Office
of Trade Adjustment Assistance (ETA),
U.S. Department of Labor, 200
Constitution Avenue, NW., Washington,
DC 20210 or tofoiarequest@dol.gov.
These determinations also are available
on the Department’s Web site at
https://www.doleta.gov/tradeact under
the searchable listing of determinations.
Dated: October 20, 2011.
Michael W. Jaffe,
Certifying Officer, Office of Trade Adjustment
Assistance.
[FR Doc. 2011–27847 Filed 10–26–11; 8:45 am]
BILLING CODE 4510–FN–P
DEPARTMENT OF LABOR
Employment and Training
Administration
Investigations Regarding Certifications
of Eligibility To Apply for Worker
Adjustment Assistance and Alternative
Trade Adjustment Assistance
Petitions have been filed with the
Secretary of Labor under Section 221(a)
of the Trade Act of 1974 (‘‘the Act’’) and
are identified in the Appendix to this
notice. Upon receipt of these petitions,
the Director of the Division of Trade
Adjustment Assistance, Employment
and Training Administration, has
instituted investigations pursuant to
Section 221(a) of the Act.
The purpose of each of the
investigations is to determine whether
the workers are eligible to apply for
adjustment assistance under title II,
chapter 2, of the Act. The investigations
will further relate, as appropriate, to the
determination of the date on which total
or partial separations began or
threatened to begin and the subdivision
of the firm involved.
The petitioners or any other persons
showing a substantial interest in the
subject matter of the investigations may
request a public hearing, provided such
request is filed in writing with the
Director, Office of Trade Adjustment
Assistance, at the address shown below,
not later than November 7, 2011.
Interested persons are invited to
submit written comments regarding the
subject matter of the investigations to
the Director, Office of Trade Adjustment
Assistance, at the address shown below,
not later than November 7, 2011.
The petitions filed in this case are
available for inspection at the Office of
the Director, Office of Trade Adjustment
Assistance, Employment and Training
Administration, U.S. Department of
Labor, Room N–5428, 200 Constitution
Avenue NW., Washington, DC 20210.
Signed at Washington, DC, this 20th day of
October 2011.
Michael Jaffe,
Certifying Officer, Office of Trade Adjustment
Assistance.
APPENDIX
[20 TAA petitions instituted between 10/10/11 and 10/14/11]
Subject firm
(petitioners)
Location
IBM (State/One-Stop) ...............................................................
TT Electronics (Company) .......................................................
LexisNexis (Company) .............................................................
Viam Manufacturing, Inc. (Company) ......................................
BASF Corporation (Company) .................................................
Haldex (State/One-Stop) ..........................................................
JVC–USA Product Return Center (State/One-Stop) ...............
Kerry Ingredients & Flavours (Union) ......................................
Stateline Warehouse (Workers) ...............................................
ON Semiconductor (Company) ................................................
Suntron Corporation (Company) ..............................................
Specialty Bar Products Co. (Workers) .....................................
Pilgrim’s Pride—Dallas Processing Plant (State/One-Stop) ....
Centurion Medical Products (Workers) ....................................
Intier Magna (State/One-Stop) .................................................
AI Android Industries (State/One-Stop) ...................................
Travelers (Workers) .................................................................
AGS Automotive (State/One-Stop) ..........................................
KV Pharmaceuticals (State/One-Stop) ....................................
Verso Paper Corp. (Union) ......................................................
San Francisco, CA ..................
Boone, NC ..............................
Miamisburg, OH ......................
Santa Fe Springs, CA .............
Belvidere, NJ ..........................
Kansas City, MO .....................
McAllen, TX ............................
Turtle Lake, WI .......................
Ridgeway, VA .........................
Phoenix, AZ ............................
Sugar Land, TX ......................
Blairsville, PA ..........................
Dallas, TX ...............................
Jeanette, PA ...........................
Shreveport, LA ........................
Shreveport, LA ........................
Elmira, NY ...............................
Shreveport, LA ........................
Bridgeton, MO .........................
Bucksport, ME ........................
TA–W
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80508
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80510
80511
80512
80513
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80515
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[FR Doc. 2011–27846 Filed 10–26–11; 8:45 am]
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Copyright Office
[Docket No. 2011–10]
Remedies for Small Copyright Claims
Copyright Office, Library of
Congress.
ACTION:
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The U.S. Copyright Office is
undertaking a study at the request of
Congress to assess whether and, if so,
how the current legal system hinders or
prevents copyright owners from
pursuing copyright infringement claims
that have a relatively small economic
value (‘‘small copyright claims’’); and
recommend potential changes in
administrative, regulatory, and statutory
authority to improve the adjudication of
these small copyright claims. The Office
SUMMARY:
LIBRARY OF CONGRESS
BILLING CODE 4510–FN–P
AGENCY:
Date of
institution
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wreier-aviles on DSK7SPTVN1PROD with NOTICES
thus seeks comment on how copyright
owners have handled small copyright
claims and the obstacles they have
encountered, as well as potential
alternatives to the current legal system
that could better accommodate such
claims. This is a general inquiry and the
Office will publish additional notices on
this topic.
DATES: Comments are due January 16,
2012.
ADDRESSES: All comments and reply
comments shall be submitted
electronically. A comment page
containing a comment form is posted on
the Office Web site at https://www.
copyright.gov/docs/smallclaims. The
Web site interface requires submitters to
complete a form specifying name and
organization, as applicable, and to
upload comments as an attachment via
a browser button. To meet accessibility
standards, submitters must upload
comments in a single file not to exceed
six megabytes (MB) in one of the
following formats: the Adobe Portable
Document File (PDF) format that
contains searchable, accessible text (not
an image); Microsoft Word;
WordPerfect; Rich Text Format (RTF); or
ASCII text file format (not a scanned
document). The form and face of the
comments must include both the name
of the submitter and organization. The
Office will post all comments publicly
on the Office’s Web site exactly as they
are received, along with names and
organizations. If electronic submission
of comments is not feasible, please
contact the Office at 202–707–8380 for
special instructions.
FOR FURTHER INFORMATION CONTACT:
Catherine Rowland, Counsel, Office of
Policy and International Affairs, by
telephone at 202–707–8350 or by
electronic mail at crowland@loc.gov.
SUPPLEMENTARY INFORMATION:
I. Background
The Copyright Act (the ‘‘Act’’), 17
U.S.C. 101 et seq., protects a wide
variety of works of authorship, ranging
from individual articles or photographs
that may not have a high commercial
value to motion pictures worth
hundreds of millions of dollars in the
marketplace. Copyright owners of all of
these works may seek remedies under
the federal Copyright Act in the event of
infringement. Not all of these copyright
owners, however, have the same
resources to bring a federal lawsuit,
which can require substantial time,
money, and effort. To the extent an
infringement results in a relatively small
amount of economic damage, the
copyright owner may be dissuaded from
filing a lawsuit because the potential
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award may not justify the expense of
litigation. Even where statutory damages
and attorney fees are possible, they are
not available until the conclusion of the
litigation. Moreover, awards of statutory
damages may be as low as $750 (or, in
cases of innocent infringement, $200),
and may not always make the copyright
owner whole.
In light of these challenges, the House
of Representatives’ Subcommittee on
Courts, the Internet, and Intellectual
Property held a hearing in March 2006
to learn more about the problems faced
by small copyright claimants (the
‘‘Small Claims Hearing’’).1 The hearing
focused on possible alternative dispute
resolution systems such as a copyright
‘‘small claims court’’ or other
mechanism. The testimony also
addressed some of the problems that
small copyright claim owners have with
the current system, as well as concerns
about defendants’ rights in an
alternative system. The Copyright Office
submitted a statement to the
Subcommittee regarding the small
copyright claims issue, noting these
difficulties, proposing to review
potential alternatives, and welcoming
the possibility of further study.2 The
Copyright Office also identified some of
these ‘‘small claims’’ challenges in its
2006 Report on Orphan Works,3 and
proposed legislation in 2006 and 2008
addressing orphan works included
provisions that specifically directed the
Copyright Office to conduct a study
addressing remedies for small claims,
but the legislation ultimately did not
become law.4
The Chairman of the House Judiciary
Committee has recently asked the U.S.
Copyright Office to study the obstacles
facing small copyright claims disputes,
as well as possible alternatives. In a
letter dated October 11, 2011, Chairman
Lamar Smith requested that the Office
‘‘undertake a study to assess: (1) The
extent to which authors and other
1 Remedies for Small Copyright Claims, Before the
Subcomm. on Courts, the Internet, and Intellectual
Property of the H. Comm. on the Judiciary, 109th
Cong. (2006), available at https://frwebgate.
access.gpo.gov/cgi-bin/getdoc.cgi?dbname=109_
house_hearings&docid=f:26767.pdf.
2 Remedies for Small Copyright Claims, Before the
Subcomm. on Courts, the Internet, and Intellectual
Property of the H. Comm. on the Judiciary, 109th
Cong. (2006) (statement of the United States
Copyright Office), available at https://
www.copyright.gov/docs/regstat032906.html.
3 United States Copyright Office, Report on
Orphan Works 1 (2006), available at https://
www.copyright.gov/orphan/orphan-report-full.pdf.
4 Proposed bills include the Shawn Bentley
Orphan Works Act of 2008, S. 2913, 110th Cong.
(2008), which was passed by the Senate; the Orphan
Works Act of 2008, H.R. 5889, 110th Cong. (2008);
and the Orphan Works Act of 2006, H.R. 5439,
109th Cong. (2006).
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copyright owners are effectively
prevented from seeking relief from
infringements due to constraints in the
current system; and (2) furnish specific
recommendations, as appropriate, for
changes in administrative, regulatory
and statutory authority that will
improve the adjudication of small
copyright claims and thereby enable all
copyright owners to more fully realize
the promise of exclusive rights
enshrined in our Constitution.’’
The Office therefore seeks comments
on how parties—both copyright owners
and those alleged to have infringed—
view the current system, what their
experiences with the current system
have been, and what types of
alternatives would be helpful and
viable.
A. Challenges of the Current Legal
System
Currently, copyright owners
interested in bringing a lawsuit to
enforce their copyrights must do so in
federal district courts, which have
exclusive jurisdiction over copyright
claims. 28 U.S.C. 1338. This is true
regardless of the monetary value of the
copyright claim. Vesting exclusive
jurisdiction in federal courts is generally
beneficial because copyright law is
federal law, and federal courts have
become familiar with copyright analysis
and thus should bring a level of
consistency to copyright cases.
Additionally, the Act aids some
copyright claimants by permitting
awards of reasonable attorney’s fees and
statutory damages to the prevailing
party, but a plaintiff may recover
statutory damages and attorney’s fees
only if the work was timely registered.
17 U.S.C. 412, 504, 505.
Despite the benefits of the current
system, there are some drawbacks to
requiring copyright owners and
defendants to engage in potentially
extensive federal litigation for all
copyright disputes. One of the major
impediments to federal lawsuits is the
cost of litigation. Although copyright
owners could proceed pro se in federal
court, they often need the assistance of
a lawyer to understand and handle
federal procedures and substantive law.
This is especially true because, unlike
in the state court system, there is no
streamlined ‘‘small claims’’ process for
claims with a lower monetary value. If
a copyright owner hires a lawyer, the
expenses can add up quickly.
Contingency fee arrangements are
relatively rare in copyright lawsuits;
thus most copyright owners will have to
pay an hourly fee for representation.
Lawyers charge hundreds of dollars per
hour, which could reach a total of tens
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or hundreds of thousands of dollars
when a case does not immediately settle
and instead requires discovery, motion
practice, and trial. In fact, one recent
survey found that, as of 2011, the
median cost for litigating a copyright
infringement lawsuit with less than
$1 million at risk was $350,000. Am.
Intellectual Prop. Law Ass’n (‘‘AIPLA’’),
Report of the Economic Survey 2011 35
(2011). Even if a copyright owner
proceeds pro se, litigation itself includes
court costs and fees, which can add up
to a not insignificant sum. Many
individual copyright owners simply do
not have the resources to fund
expensive litigation. Moreover, even
though the Act allows some awards of
attorney’s fees, other costs, and statutory
damages, these awards are not
guaranteed—and may not be available at
all depending on the timeliness of
copyright registration—and are only
awarded at the end of litigation, likely
after a copyright owner has made
significant out of pocket payment to
cover legal fees and court costs.
Additionally, an award of attorney’s
fees—assuming that it is collectible—
will not necessarily reimburse the
copyright owner for all fees expended in
prosecuting a claim.
In federal litigation, the period of time
between the filing of a case and the final
determination can be lengthy. The
Federal Rules of Civil Procedure allow
parties to engage in extensive discovery
and motion practice, which often take
far more than a year to complete. In fact,
the median time for all cases that went
to trial—not just copyright suits—was
twenty-three months in 2009–2010.5
This lengthy time frame requires
litigants to expend energy and effort
throughout a relatively long period of
time. This investment of time, not to
mention the associated expenses, may
not be feasible for individual authors,
who may not be able to dedicate
sufficient time to handle all of the
litigation burdens.
wreier-aviles on DSK7SPTVN1PROD with NOTICES
B. Potential Alternatives for Small
Copyright Claims
The Office is interested in learning
about alternatives to the current legal
system that might help alleviate some of
the burdens associated with pursuing
small copyright claims. Some
5 Federal Judicial Caseload Statistics, March 31,
2010, Office of Judges Programs, Statistics Division,
Administrative Office of the United States Courts,
Table C–5, available at https://www.uscourts.gov/
Viewer.aspx?doc=/uscourts/Statistics/
FederalJudicialCaseloadStatistics/2010/tables/
C05Mar10.pdf. The time frame differs significantly
between districts—from 11.1 months in the U.S.
District Court for the Eastern District of Virginia to
41.2 months in the U.S. District Court for the
District of Columbia.
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alternatives were identified at the Small
Claims Hearing, including: (1) Using the
current Copyright Royalty Board (a
panel of administrative law judges
established under Chapter 8 of Title 17
that sets rates and terms for statutory
licenses and decides how to distribute
certain statutory license royalties); (2)
creating a federal ‘‘small claims court’’
or otherwise streamlining federal
procedures; (3) developing a staff of
dedicated administrative law judges to
specialize in small copyright claims; (4)
amending the Act to allow state courts
(including small claims courts) to hear
small copyright claims; and (5) allowing
trade associations or other group
representatives to bring a single, large
filing on behalf of a sizeable group of
small copyright owners. While these
alternatives deserve balanced
discussion, there may be other
potentially suitable options that were
not discussed at the Small Claims
Hearing.
There are, of course, a variety of
issues that require further consideration.
These include:
Degree of Difficulty Litigating Small
Copyright Claims in the Current System:
Before analyzing various alternatives to
the current system, it is important to
further explore the obstacles that the
district court process presents in small
copyright claim cases. This would help
focus future analysis and any potential
alternative legal processes.
State Court Involvement: State courts
do not have expertise in copyright
jurisprudence. As noted above, Section
1338 of Title 28 of the U.S. Code vests
federal courts with exclusive
jurisdiction over copyright claims.
Moreover, Section 301 of the Act
explicitly preempts state claims ‘‘that
are equivalent to any of the exclusive
rights within the general scope of
copyright as specified by section 106 in
works of authorship that are fixed in a
tangible medium of expression and
come within the subject matter of
copyright as specified by sections 102
and 103.’’ Thus, state courts are not
experienced in the nuances of copyright
law and may not have sufficient
resources to devote to a claim’s
intricacies, especially when limited in a
small claims court context.
Nevertheless, state courts commonly
handle small disputes, and thus they
likely have the structure to handle the
logistics of such claims. State court
involvement, however, is only one
possible avenue to explore and there are
also several federal options that should
be considered in the discussion.
Location of Federal Court/Tribunal:
Creating a federal ‘‘small claims court’’
or administrative judge panel would
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create logistical rather than
jurisdictional challenges, including
where the court(s) and panel(s) would
be located. If there are several courts or
panels located throughout the country,
it may provide more convenience to the
parties, but it may also reduce
consistency and add to administrative
costs. Alternatively, if there is only one
court or panel, the guiding rules could
allow for liberal use of telephone
conferences and videoconferences, and
the procedures could focus more on a
paper practice with fewer (if any)
hearings. The court or tribunal could
also limit the types and amount of
discovery in the interest of expediency.
Affiliation With the Copyright Office
or Copyright Royalty Board: The
Copyright Office administers the
Copyright Act, is a substantive expert on
provisions of copyright law, and has
statutory responsibilities in both
litigation and administrative law. It may
thus be appropriate for the Office to be
associated with a new process.
Similarly, the Copyright Royalty Board
is already proficient in handling
administrative procedures under the
Act, and it may have the capability of
expanding its scope to handle
additional claims.
Determination of ‘‘Small’’ Copyright
Claims: Although many copyright
owners are concerned about the cost of
litigating ‘‘small’’ copyright claims in
federal court, the definition of ‘‘small’’
is unclear. Any changes in legal process
must take a balanced approach to
determine which claims are deemed
‘‘small’’ enough to fit into the new
system.
Voluntary or Mandatory: A major
question is whether a new small
copyright claim process would be
voluntary or mandatory. Copyright
owners may want the option of choosing
which type of court hears a claim, and
defendants might similarly wish to
remove a claim filed in a new court or
panel to federal district court.
Additionally, the question arises about
how to appeal an adverse decision—and
to what court or other body.
Fair Use: The affirmative defense of
fair use defense is extremely factspecific and typically requires courts to
examine decades of judicial precedent.
The ability to present and have heard a
fair use defense is therefore a concern.
Defendants’ Appearance: It has been
suggested that defendants should not be
required to appear at a small copyright
claim proceeding until the copyright
owner provides a prima facie case of
infringement. This ostensibly would
prevent a copyright owner from
dragging a defendant into a legal
proceeding without cause. It is unclear
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whether this would be necessary, or
whether an alternative small copyright
claims proceeding might instead rely
upon a rule akin to Federal Rule of Civil
Procedure 11, which requires plaintiffs
to certify the veracity of the claim.
Available Remedies: Because a small
copyright claim process likely would be
limited to reduce costs and time, it is
unclear what types of remedies should
be offered. The Act itself offers a
number of infringement remedies,
including injunctions, monetary relief
(including statutory damages),
impounding of infringing copies and of
the articles by means of which
infringing copies may be reproduced,
costs and attorney’s fees. Consideration
should be given to whether an
alternative small claims process could
or should provide this whole panoply of
remedies, and whether the new system
would also allow preliminary relief to
prevent impending or continuing
infringement, similar to a temporary
restraining order or preliminary
injunction under Federal Rule of Civil
Procedure 65.
These are but a few of the factors to
analyze before deciding whether to
move forward with a new small
copyright claim system, and, if so, what
that new process might be.
II. Subjects of Inquiry
The Office seeks comment on how
copyright owners and defendants use
the current legal system for small
copyright claims, including information
on the obstacles and benefits of using
federal district courts. Additionally, the
Office requests comment on potential
alternatives for handling copyright
claims that have a relatively small
economic value. The Office is interested
in comment on the logistics of potential
alternatives, as well as the benefits and
risks presented by different types of
processes.
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III. Conclusion
The Office hereby seeks comment
from the public on factual and policy
matters related to the treatment of small
copyright claims. If there are any
additional pertinent issues not
discussed above, the Office encourages
interested parties to raise those matters
in their comments. In addition, the
Office is considering having one or more
roundtables or formal hearings on the
matters raised above in the coming
months. It is also likely that, following
receipt of the comments in response to
this Notice, the Office will publish a
further Notice of Inquiry posing specific
questions and possibly exploring
additional alternatives.
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Dated: October 24, 2011.
Maria A. Pallante,
Register of Copyrights.
[FR Doc. 2011–27824 Filed 10–26–11; 8:45 am]
BILLING CODE 1410–30–P
NATIONAL ARCHIVES AND RECORDS
ADMINISTRATION
Records Schedules; Availability and
Request for Comments
National Archives and Records
Administration (NARA).
ACTION: Notice of availability of
proposed records schedules; request for
comments.
AGENCY:
The National Archives and
Records Administration (NARA)
publishes notice at least once monthly
of certain Federal agency requests for
records disposition authority (records
schedules). Once approved by NARA,
records schedules provide mandatory
instructions on what happens to records
when no longer needed for current
Government business. They authorize
the preservation of records of
continuing value in the National
Archives of the United States and the
destruction, after a specified period, of
records lacking administrative, legal,
research, or other value. Notice is
published for records schedules in
which agencies propose to destroy
records not previously authorized for
disposal or reduce the retention period
of records already authorized for
disposal. NARA invites public
comments on such records schedules, as
required by 44 U.S.C. 3303a(a).
DATES: Requests for copies must be
received in writing on or before
November 28, 2011. Once the appraisal
of the records is completed, NARA will
send a copy of the schedule. NARA staff
usually prepare appraisal
memorandums that contain additional
information concerning the records
covered by a proposed schedule. These,
too, may be requested and will be
provided once the appraisal is
completed. Requesters will be given 30
days to submit comments.
ADDRESSES: You may request a copy of
any records schedule identified in this
notice by contacting Records
Management Services (ACNR) using one
of the following means:
Mail: NARA (ACNR), 8601 Adelphi
Road, College Park, MD 20740–6001.
E-mail: request.schedule@nara.gov.
Fax: 301–837–3698.
Requesters must cite the control
number, which appears in parentheses
after the name of the agency which
SUMMARY:
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submitted the schedule, and must
provide a mailing address. Those who
desire appraisal reports should so
indicate in their request.
FOR FURTHER INFORMATION CONTACT:
Laurence Brewer, Director, National
Records Management Program (ACN),
National Archives and Records
Administration, 8601 Adelphi Road,
College Park, MD 20740–6001.
Telephone: 301–837–1539. E-mail:
request.schedule@nara.gov.
SUPPLEMENTARY INFORMATION: Each year
Federal agencies create billions of
records on paper, film, magnetic tape,
and other media. To control this
accumulation, agency records managers
prepare schedules proposing retention
periods for records and submit these
schedules for NARA’s approval, using
the Standard Form (SF) 115, Request for
Records Disposition Authority. These
schedules provide for the timely transfer
into the National Archives of
historically valuable records and
authorize the disposal of all other
records after the agency no longer needs
them to conduct its business. Some
schedules are comprehensive and cover
all the records of an agency or one of its
major subdivisions. Most schedules,
however, cover records of only one
office or program or a few series of
records. Many of these update
previously approved schedules, and
some include records proposed as
permanent.
The schedules listed in this notice are
media neutral unless specified
otherwise. An item in a schedule is
media neutral when the disposition
instructions may be applied to records
regardless of the medium in which the
records are created and maintained.
Items included in schedules submitted
to NARA on or after December 17, 2007,
are media neutral unless the item is
limited to a specific medium. (See 36
CFR 1225.12(e).)
No Federal records are authorized for
destruction without the approval of the
Archivist of the United States. This
approval is granted only after a
thorough consideration of their
administrative use by the agency of
origin, the rights of the Government and
of private persons directly affected by
the Government’s activities, and
whether or not they have historical or
other value.
Besides identifying the Federal
agencies and any subdivisions
requesting disposition authority, this
public notice lists the organizational
unit(s) accumulating the records or
indicates agency-wide applicability in
the case of schedules that cover records
that may be accumulated throughout an
E:\FR\FM\27OCN1.SGM
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Agencies
[Federal Register Volume 76, Number 208 (Thursday, October 27, 2011)]
[Notices]
[Pages 66758-66761]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-27824]
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LIBRARY OF CONGRESS
Copyright Office
[Docket No. 2011-10]
Remedies for Small Copyright Claims
AGENCY: Copyright Office, Library of Congress.
ACTION: Notice of inquiry.
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SUMMARY: The U.S. Copyright Office is undertaking a study at the
request of Congress to assess whether and, if so, how the current legal
system hinders or prevents copyright owners from pursuing copyright
infringement claims that have a relatively small economic value
(``small copyright claims''); and recommend potential changes in
administrative, regulatory, and statutory authority to improve the
adjudication of these small copyright claims. The Office
[[Page 66759]]
thus seeks comment on how copyright owners have handled small copyright
claims and the obstacles they have encountered, as well as potential
alternatives to the current legal system that could better accommodate
such claims. This is a general inquiry and the Office will publish
additional notices on this topic.
DATES: Comments are due January 16, 2012.
ADDRESSES: All comments and reply comments shall be submitted
electronically. A comment page containing a comment form is posted on
the Office Web site at https://www.copyright.gov/docs/smallclaims. The
Web site interface requires submitters to complete a form specifying
name and organization, as applicable, and to upload comments as an
attachment via a browser button. To meet accessibility standards,
submitters must upload comments in a single file not to exceed six
megabytes (MB) in one of the following formats: the Adobe Portable
Document File (PDF) format that contains searchable, accessible text
(not an image); Microsoft Word; WordPerfect; Rich Text Format (RTF); or
ASCII text file format (not a scanned document). The form and face of
the comments must include both the name of the submitter and
organization. The Office will post all comments publicly on the
Office's Web site exactly as they are received, along with names and
organizations. If electronic submission of comments is not feasible,
please contact the Office at 202-707-8380 for special instructions.
FOR FURTHER INFORMATION CONTACT: Catherine Rowland, Counsel, Office of
Policy and International Affairs, by telephone at 202-707-8350 or by
electronic mail at crowland@loc.gov.
SUPPLEMENTARY INFORMATION:
I. Background
The Copyright Act (the ``Act''), 17 U.S.C. 101 et seq., protects a
wide variety of works of authorship, ranging from individual articles
or photographs that may not have a high commercial value to motion
pictures worth hundreds of millions of dollars in the marketplace.
Copyright owners of all of these works may seek remedies under the
federal Copyright Act in the event of infringement. Not all of these
copyright owners, however, have the same resources to bring a federal
lawsuit, which can require substantial time, money, and effort. To the
extent an infringement results in a relatively small amount of economic
damage, the copyright owner may be dissuaded from filing a lawsuit
because the potential award may not justify the expense of litigation.
Even where statutory damages and attorney fees are possible, they are
not available until the conclusion of the litigation. Moreover, awards
of statutory damages may be as low as $750 (or, in cases of innocent
infringement, $200), and may not always make the copyright owner whole.
In light of these challenges, the House of Representatives'
Subcommittee on Courts, the Internet, and Intellectual Property held a
hearing in March 2006 to learn more about the problems faced by small
copyright claimants (the ``Small Claims Hearing'').\1\ The hearing
focused on possible alternative dispute resolution systems such as a
copyright ``small claims court'' or other mechanism. The testimony also
addressed some of the problems that small copyright claim owners have
with the current system, as well as concerns about defendants' rights
in an alternative system. The Copyright Office submitted a statement to
the Subcommittee regarding the small copyright claims issue, noting
these difficulties, proposing to review potential alternatives, and
welcoming the possibility of further study.\2\ The Copyright Office
also identified some of these ``small claims'' challenges in its 2006
Report on Orphan Works,\3\ and proposed legislation in 2006 and 2008
addressing orphan works included provisions that specifically directed
the Copyright Office to conduct a study addressing remedies for small
claims, but the legislation ultimately did not become law.\4\
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\1\ Remedies for Small Copyright Claims, Before the Subcomm. on
Courts, the Internet, and Intellectual Property of the H. Comm. on
the Judiciary, 109th Cong. (2006), available at https://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=109_house_hearings&docid=f:26767.pdf.
\2\ Remedies for Small Copyright Claims, Before the Subcomm. on
Courts, the Internet, and Intellectual Property of the H. Comm. on
the Judiciary, 109th Cong. (2006) (statement of the United States
Copyright Office), available at https://www.copyright.gov/docs/regstat032906.html.
\3\ United States Copyright Office, Report on Orphan Works 1
(2006), available at https://www.copyright.gov/orphan/orphan-report-full.pdf.
\4\ Proposed bills include the Shawn Bentley Orphan Works Act of
2008, S. 2913, 110th Cong. (2008), which was passed by the Senate;
the Orphan Works Act of 2008, H.R. 5889, 110th Cong. (2008); and the
Orphan Works Act of 2006, H.R. 5439, 109th Cong. (2006).
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The Chairman of the House Judiciary Committee has recently asked
the U.S. Copyright Office to study the obstacles facing small copyright
claims disputes, as well as possible alternatives. In a letter dated
October 11, 2011, Chairman Lamar Smith requested that the Office
``undertake a study to assess: (1) The extent to which authors and
other copyright owners are effectively prevented from seeking relief
from infringements due to constraints in the current system; and (2)
furnish specific recommendations, as appropriate, for changes in
administrative, regulatory and statutory authority that will improve
the adjudication of small copyright claims and thereby enable all
copyright owners to more fully realize the promise of exclusive rights
enshrined in our Constitution.''
The Office therefore seeks comments on how parties--both copyright
owners and those alleged to have infringed--view the current system,
what their experiences with the current system have been, and what
types of alternatives would be helpful and viable.
A. Challenges of the Current Legal System
Currently, copyright owners interested in bringing a lawsuit to
enforce their copyrights must do so in federal district courts, which
have exclusive jurisdiction over copyright claims. 28 U.S.C. 1338. This
is true regardless of the monetary value of the copyright claim.
Vesting exclusive jurisdiction in federal courts is generally
beneficial because copyright law is federal law, and federal courts
have become familiar with copyright analysis and thus should bring a
level of consistency to copyright cases. Additionally, the Act aids
some copyright claimants by permitting awards of reasonable attorney's
fees and statutory damages to the prevailing party, but a plaintiff may
recover statutory damages and attorney's fees only if the work was
timely registered. 17 U.S.C. 412, 504, 505.
Despite the benefits of the current system, there are some
drawbacks to requiring copyright owners and defendants to engage in
potentially extensive federal litigation for all copyright disputes.
One of the major impediments to federal lawsuits is the cost of
litigation. Although copyright owners could proceed pro se in federal
court, they often need the assistance of a lawyer to understand and
handle federal procedures and substantive law. This is especially true
because, unlike in the state court system, there is no streamlined
``small claims'' process for claims with a lower monetary value. If a
copyright owner hires a lawyer, the expenses can add up quickly.
Contingency fee arrangements are relatively rare in copyright lawsuits;
thus most copyright owners will have to pay an hourly fee for
representation. Lawyers charge hundreds of dollars per hour, which
could reach a total of tens
[[Page 66760]]
or hundreds of thousands of dollars when a case does not immediately
settle and instead requires discovery, motion practice, and trial. In
fact, one recent survey found that, as of 2011, the median cost for
litigating a copyright infringement lawsuit with less than $1 million
at risk was $350,000. Am. Intellectual Prop. Law Ass'n (``AIPLA''),
Report of the Economic Survey 2011 35 (2011). Even if a copyright owner
proceeds pro se, litigation itself includes court costs and fees, which
can add up to a not insignificant sum. Many individual copyright owners
simply do not have the resources to fund expensive litigation.
Moreover, even though the Act allows some awards of attorney's fees,
other costs, and statutory damages, these awards are not guaranteed--
and may not be available at all depending on the timeliness of
copyright registration--and are only awarded at the end of litigation,
likely after a copyright owner has made significant out of pocket
payment to cover legal fees and court costs. Additionally, an award of
attorney's fees--assuming that it is collectible--will not necessarily
reimburse the copyright owner for all fees expended in prosecuting a
claim.
In federal litigation, the period of time between the filing of a
case and the final determination can be lengthy. The Federal Rules of
Civil Procedure allow parties to engage in extensive discovery and
motion practice, which often take far more than a year to complete. In
fact, the median time for all cases that went to trial--not just
copyright suits--was twenty-three months in 2009-2010.\5\ This lengthy
time frame requires litigants to expend energy and effort throughout a
relatively long period of time. This investment of time, not to mention
the associated expenses, may not be feasible for individual authors,
who may not be able to dedicate sufficient time to handle all of the
litigation burdens.
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\5\ Federal Judicial Caseload Statistics, March 31, 2010, Office
of Judges Programs, Statistics Division, Administrative Office of
the United States Courts, Table C-5, available at https://www.uscourts.gov/Viewer.aspx?doc=/uscourts/Statistics/FederalJudicialCaseloadStatistics/2010/tables/C05Mar10.pdf. The time
frame differs significantly between districts--from 11.1 months in
the U.S. District Court for the Eastern District of Virginia to 41.2
months in the U.S. District Court for the District of Columbia.
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B. Potential Alternatives for Small Copyright Claims
The Office is interested in learning about alternatives to the
current legal system that might help alleviate some of the burdens
associated with pursuing small copyright claims. Some alternatives were
identified at the Small Claims Hearing, including: (1) Using the
current Copyright Royalty Board (a panel of administrative law judges
established under Chapter 8 of Title 17 that sets rates and terms for
statutory licenses and decides how to distribute certain statutory
license royalties); (2) creating a federal ``small claims court'' or
otherwise streamlining federal procedures; (3) developing a staff of
dedicated administrative law judges to specialize in small copyright
claims; (4) amending the Act to allow state courts (including small
claims courts) to hear small copyright claims; and (5) allowing trade
associations or other group representatives to bring a single, large
filing on behalf of a sizeable group of small copyright owners. While
these alternatives deserve balanced discussion, there may be other
potentially suitable options that were not discussed at the Small
Claims Hearing.
There are, of course, a variety of issues that require further
consideration. These include:
Degree of Difficulty Litigating Small Copyright Claims in the
Current System: Before analyzing various alternatives to the current
system, it is important to further explore the obstacles that the
district court process presents in small copyright claim cases. This
would help focus future analysis and any potential alternative legal
processes.
State Court Involvement: State courts do not have expertise in
copyright jurisprudence. As noted above, Section 1338 of Title 28 of
the U.S. Code vests federal courts with exclusive jurisdiction over
copyright claims. Moreover, Section 301 of the Act explicitly preempts
state claims ``that are equivalent to any of the exclusive rights
within the general scope of copyright as specified by section 106 in
works of authorship that are fixed in a tangible medium of expression
and come within the subject matter of copyright as specified by
sections 102 and 103.'' Thus, state courts are not experienced in the
nuances of copyright law and may not have sufficient resources to
devote to a claim's intricacies, especially when limited in a small
claims court context. Nevertheless, state courts commonly handle small
disputes, and thus they likely have the structure to handle the
logistics of such claims. State court involvement, however, is only one
possible avenue to explore and there are also several federal options
that should be considered in the discussion.
Location of Federal Court/Tribunal: Creating a federal ``small
claims court'' or administrative judge panel would create logistical
rather than jurisdictional challenges, including where the court(s) and
panel(s) would be located. If there are several courts or panels
located throughout the country, it may provide more convenience to the
parties, but it may also reduce consistency and add to administrative
costs. Alternatively, if there is only one court or panel, the guiding
rules could allow for liberal use of telephone conferences and
videoconferences, and the procedures could focus more on a paper
practice with fewer (if any) hearings. The court or tribunal could also
limit the types and amount of discovery in the interest of expediency.
Affiliation With the Copyright Office or Copyright Royalty Board:
The Copyright Office administers the Copyright Act, is a substantive
expert on provisions of copyright law, and has statutory
responsibilities in both litigation and administrative law. It may thus
be appropriate for the Office to be associated with a new process.
Similarly, the Copyright Royalty Board is already proficient in
handling administrative procedures under the Act, and it may have the
capability of expanding its scope to handle additional claims.
Determination of ``Small'' Copyright Claims: Although many
copyright owners are concerned about the cost of litigating ``small''
copyright claims in federal court, the definition of ``small'' is
unclear. Any changes in legal process must take a balanced approach to
determine which claims are deemed ``small'' enough to fit into the new
system.
Voluntary or Mandatory: A major question is whether a new small
copyright claim process would be voluntary or mandatory. Copyright
owners may want the option of choosing which type of court hears a
claim, and defendants might similarly wish to remove a claim filed in a
new court or panel to federal district court. Additionally, the
question arises about how to appeal an adverse decision--and to what
court or other body.
Fair Use: The affirmative defense of fair use defense is extremely
fact-specific and typically requires courts to examine decades of
judicial precedent. The ability to present and have heard a fair use
defense is therefore a concern.
Defendants' Appearance: It has been suggested that defendants
should not be required to appear at a small copyright claim proceeding
until the copyright owner provides a prima facie case of infringement.
This ostensibly would prevent a copyright owner from dragging a
defendant into a legal proceeding without cause. It is unclear
[[Page 66761]]
whether this would be necessary, or whether an alternative small
copyright claims proceeding might instead rely upon a rule akin to
Federal Rule of Civil Procedure 11, which requires plaintiffs to
certify the veracity of the claim.
Available Remedies: Because a small copyright claim process likely
would be limited to reduce costs and time, it is unclear what types of
remedies should be offered. The Act itself offers a number of
infringement remedies, including injunctions, monetary relief
(including statutory damages), impounding of infringing copies and of
the articles by means of which infringing copies may be reproduced,
costs and attorney's fees. Consideration should be given to whether an
alternative small claims process could or should provide this whole
panoply of remedies, and whether the new system would also allow
preliminary relief to prevent impending or continuing infringement,
similar to a temporary restraining order or preliminary injunction
under Federal Rule of Civil Procedure 65.
These are but a few of the factors to analyze before deciding
whether to move forward with a new small copyright claim system, and,
if so, what that new process might be.
II. Subjects of Inquiry
The Office seeks comment on how copyright owners and defendants use
the current legal system for small copyright claims, including
information on the obstacles and benefits of using federal district
courts. Additionally, the Office requests comment on potential
alternatives for handling copyright claims that have a relatively small
economic value. The Office is interested in comment on the logistics of
potential alternatives, as well as the benefits and risks presented by
different types of processes.
III. Conclusion
The Office hereby seeks comment from the public on factual and
policy matters related to the treatment of small copyright claims. If
there are any additional pertinent issues not discussed above, the
Office encourages interested parties to raise those matters in their
comments. In addition, the Office is considering having one or more
roundtables or formal hearings on the matters raised above in the
coming months. It is also likely that, following receipt of the
comments in response to this Notice, the Office will publish a further
Notice of Inquiry posing specific questions and possibly exploring
additional alternatives.
Dated: October 24, 2011.
Maria A. Pallante,
Register of Copyrights.
[FR Doc. 2011-27824 Filed 10-26-11; 8:45 am]
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