APA’s specific responses to certain of the Copyright Office’s questions are set forth
APA Advises US Copyright Office on Improving Copyright Registration Process
When registering your copyrights, have you struggled with determining whether or not your images are "published," and what date to enter for the publication date? You are not alone!
Fortunately, the Copyright Office recently sent out a "Notice of Inquiry" (NOI) on the topic of "online publication," requesting feedback from the public on improving regulations and copyright office policy and services related to determining the publication status of a work when submitting copyright registrations.
The Doniger Burroughs law firm generously worked with APA and our past President Jeff Sedlik to draft detailed responses to the questions posed by the Copyright Office.
In addition to submitting our own comments to the Copyright Office, APA participated in joint responses by Coalition of Visual Associations and the National Writers Union.
While the requirement to indicate publication status on a copyright registration can't be removed without an act of Congress, the APA has proposed solutions that would allow the Copyright Office to vastly improve and simplify registration for our members.
You can find all the responses here: https://www.regulations.gov/docketBrowser?rpp=25&po=25&dct=PS&D=COLC-2019-0003&refD=COLC-2019-0003-0001.
APA’s specific responses to certain of the Copyright Office’s questions are set forth in this PDF: Comments of American Photographic Artists NOI FR 2019-26004.