31 Jan The Guild Signs on to Comment Letter on Group Registration of Photographs
In conjunction with the Coalition of Visual Artists, the Graphic Artists Guild has signed on to a comment letter in response to a Notice of Proposed Rulemaking, “Group Registration of Photographs,” issued by the Copyright Office. In the Notice, the Copyright Office asked for feedback on proposed changes to the group registration of photographs. The letter submitted on behalf of the Coalition applauds the Copyright Office’s initiative in encouraging greater participation in the registration system by photographers, but raised concerns with some of the proposed changes. Of particular concern to Guild members, the letter raised issue with the exclusion of graphic artists from the group registration option.
In drafting the changes to the group registration of photographs, the Copyright Office is seeking to encourage copyright registration among photographers, streamline the registration process, and improve the recording of works by requiring digital deposits. However, graphic artists such as designers and illustrators are excluded from this option, despite the fact that these artists create works such as comps, sketches, and revisions that are delivered to clients and are ripe for infringement. The comment letter urges the Copyright Office to “offer a group registration category to all visual works.” It also points out that many visual works are mixed media, and that limiting the registration to still photography does not address how many artists work.
The comment letter addresses a number of other concerns with the proposed rulemaking, such as the limit of 750 photographs for the group registration (problematic for photographers, who often outstrip that number in the course of a single shoot), and the separate registration requirements for published and unpublished works.
The letter was submitted to the Copyright Office by Lisa Shaftel of Shaftel & Schmeltzer on behalf of the Coalition of Visual Artists. Signees to the letter include American Photographic Artists, American Society of Media Photographers, Digital Media Licensing Association, Graphic Artists Guild, National Press Photographers Association, North American Nature Photography Association, Professional Photographers of America, PLUS Coalition, Shaftel & Schmeltzer, and Doniger / Burroughs