CBI Files Comments on Historic Notice & Recordkeeping in Copyright Office

The Copyright Office is still trying to figure out what to do about back recordkeeping supposed to be provided by webcasters from the passage of the DMCA in October, 1998 through N, where N equals whenever the Copyright Office gets around to promulgating its interim regulations on Notice and Recordkeeping.  Toward that end the Office sought comments on what to do about past recordkeeping (which to a large extent doesn't exist).     CBI filed these comments  simply to clarify that college and nonprofit webcasters who have opted in to the May 31st Agreement with RIAA are not subject to whatever regime the Copyright Office ultimately adopts for this period.