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 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 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.

The News/Media Alliance, a nonprofit representing over 2,000 publishers, supports the Copyright Office's exploration of alternative fee structures to make registration more accessible and efficient. They advocate for innovation, including subscription pricing and bulk registration for individual online works, while cautioning against fee increases that would burden the price-sensitive news industry.

The Copyright Alliance, a non-profit organization representing over 2 million creators, supports the implementation of several alternative fee structures, including small entity fees, subscription fees, and graduated group registration fees. They argue that these structures will improve registration efficiency and encourage more robust participation in the copyright system while advocating for the inclusion of new models for digital works and graduated group fees.

The Recording Industry Association of America (RIAA), representing music labels, supports the goal of increasing copyright registrations but urges the Copyright Office to prioritize simple fee solutions that do not delay the new ECS registration system. They specifically oppose differentiating fees by work type, arguing it is unfair to creators, and advocate for bulk or batch discounts for high-volume filers and API access to improve efficiency.

The Copyright Policy Institute (CPI) supports the Copyright Office's inquiry into alternative fee structures, advocating for a "Creator Access Framework" that prioritizes accessibility for independent and small-scale creators. They argue that registration fees should be "fair and equitable," suggesting tiered, creator-sensitive fee structures and the expansion of group registration programs to ensure that economic circumstances do not prevent creators from obtaining federal copyright protection.