CO Seeks Further Comment on DMCA Section 1201 Study Proposals
The Copyright Office sought additional comment Tuesday on its study of Digital Millennium Copyright Act Section 1201 provisions on circumvention of technological protection measures (TPMs). The CO's study explores whether to adjust the office's triennial review process for granting exemptions…
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to the circumvention ban (see 1512280030). Stakeholders partially focused in initial comments on the inquiry in the study on allowing for presumptive renewal of existing Section 1201 exemptions (see 1603030090). The CO said in the Federal Register​ it wants input on possible legislative recommendations on Section 1201 not directly related to the office's triennial exemptions review process. The office said it “continues to thoroughly evaluate” comments on the triennial review process but the new round of comments “does not specifically address those issues.” Issues up for comment include proposals for new permanent Section 1201 exemptions for mobile device unlocking, assistive technologies for individuals who are blind or vision impaired, some categories of software and “obsolete” technologies. The CO said it wants more input on how the proposed exclusions would affect existing U.S. treaties and trade agreements. The CO said it wants more feedback on possible amendments to existing permanent exemptions for security testing, encryption research and reverse engineering that would address concerns that those exemptions don't adequately cover good-faith research into security flaws and vulnerabilities. The CO said it also wants comment on how the section's anti-trafficking provisions affect third parties' ability to assist in exempted TPM circumventions. Comments are due Oct. 27, replies Nov. 16.