Alternative Fee Structures for Registration

The American Society of Media Photographers, North American Nature Photography Association, and Professional Photographers of America support the implementation of alternative fee structures, specifically advocating for a "Next Generation" registration system. They argue that the current "750 at a time" group registration model is inefficient for high-volume photographers and propose subscription-based models combined with APIs and AI technology to provide cost certainty and ease of use.

The Association of American Publishers supports the U.S. Copyright Office's efforts to explore alternative fee structures to reduce costs for copyright owners and taxpayers. They suggest that the Office conduct a more granular analysis of costs by work type, explore "risk-based" examination models to lower costs, and consider tiered subscription models to provide pricing predictability for high-volume users.

Transition Music Corporation, an independent production music library, argues that current group registration options (like GRAM) are structurally unsuitable for their catalog of works-for-hire. They request the Office to create a new "Catalog Registration" or "Volume Registration" pathway with a flat fee for high-volume owners to ensure their works remain protectable and affordable to register.

The Graphic Artists Guild supports the Copyright Office's exploration of alternative fee structures but emphasizes that new models must prioritize accessibility for individual creators and small entities. They propose a framework including claimant-based eligibility, a structured registration track for illustrations to improve scalability, and a creator-focused subscription model with caps and preferential pricing.

The National Association of REALTORS® (NAR) supports the Copyright Office's consideration of alternative fee structures to encourage registration, specifically advocating for a modernized, electronic filing process for Multiple Listing Services (MLSs). They argue that the current paper-based system creates unnecessary costs and administrative burdens for MLSs, and they suggest implementing subscription models or fee structures tailored to the size of the business to ensure fairness.

The Motion Picture Association, Inc. (MPA) supports the Copyright Office's exploration of alternative fee structures to make registration more accessible, particularly for small businesses and professional creators. They advocate for models that improve efficiency, offer income-based discounts for small entities, and ensure the system remains financially self-sustaining without unfairly increasing costs for other stakeholders.

The American Association of Independent Music (A2IM), a nonprofit trade organization representing independent record labels and music businesses, supports the proposed reduced registration fee for small entities. They argue that this structure is necessary for price-sensitive independent creators who cannot pass on registration costs and urge the Copyright Office to pair this discount with improved high-capacity group registration options for music.

The law firm Larson Skinner PLLC, representing Multiple Listing Services (MLSs), advocates for the creation of an electronic and predictable recurring fee structure for group registration of updates to non-photographic databases (GRDB). They argue that the current paper-based process is inefficient and propose a capped annual or quarterly subscription model to accommodate the frequent, recurring registration needs of database owners.

The American Intellectual Property Law Association (AIPLA) supports differentiating copyright registration fees based on the type of work and the size of the applicant (specifically supporting reduced fees for small and micro entities). However, the association opposes a subscription pricing model and a fee structure based solely on individual versus organizational status.

The National Music Publishers’ Association (NMPA) supports the Copyright Office's exploration of alternative fee structures, provided they encourage registration participation without increasing costs or removing existing options. They specifically advocate for a tiered subscription-based pricing model, reduced fees for small entities (without raising fees for large ones), and improvements to the GRAM registration option to accommodate complex claimant structures.