1
BEFORE THE COPYRIGHT OFFICE
LIBRARY OF CONGRESS
IN THE MATTER OF
EXEMPTION TO THE PROHIBITION OF CIRCUMVENTION OF
COPYRIGHT PROTECTION SYSTEMS FOR ACCESS CONTROL
TECHNOLOGIES
Docket No. RM 2005-11
REPLY COMMENT OF
THE ELECTRONIC FRONTIER FOUNDATION
These reply comments are submitted on behalf of the Electronic Frontier Foundation
(EFF) in response to the Notice of Inquiry (NOI) issued by the Copyright Office and Library of
Congress regarding Exemptions to Prohibition on Circumvention of Copyright Protection
Systems for Access Control Technologies.1
EFF submits these reply comments in support of the following classes of works for which
exemptions were proposed in the initial round of comments submitted in response to the NOI:
• Audiovisual works and sound recordings distributed in digital format when all
commercially available editions contain access controls that prevent the creation of
clip compilations and other educational uses (Comment #2, proposed by Library
Copyright Alliance and Music Library Association).
• Audiovisual works included in the educational library of a college or university’s film
or media studies department and that are protected by technological measures that
prevent their educational use (Comment #5, proposed by Profs. Peter Decherney,
Michael Delli Carpini, and Katherine Sender)
• Derivative and collective works which contain audiovisual works that are in the
public domain and that are protected by technological measures that prevent their
educational use (Comment #5, proposed by Profs. Peter Decherney, Michael Delli
Carpini, and Katherine Sender).
• Computer programs that operate wireless telecommunications handsets (Comment
#3, proposed by The Wireless Alliance and Robert Pinkerton).
• Sound recordings and audiovisual works distributed in compact disc format and
protected by technological measures that impede access to lawfully purchased works
by creating or exploiting security vulnerabilities that compromise the security of
personal compu