[Federal Register Volume 80, Number 240 (Tuesday, December 15, 2015)]
[Notices]
[Pages 77668-77672]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-31411]


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LIBRARY OF CONGRESS

U.S. Copyright Office

[Docket No. 2015-6]


Software-Enabled Consumer Products Study: Notice and Request for 
Public Comment

AGENCY: U.S. Copyright Office, Library of Congress.

ACTION: Notice of inquiry.

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SUMMARY: The U.S. Copyright Office is undertaking a study at the 
request of Congress to review the role of copyright law with respect to 
software-enabled consumer products. The topics of public inquiry 
include whether the application of copyright law to software in 
everyday products enables or frustrates innovation and creativity in 
the design, distribution and legitimate uses of new products and 
innovative services. The Office also is seeking information as to 
whether legitimate interests or business models for copyright owners 
and users could be improved or undermined by changes to the copyright 
law in this area. This is a highly specific study not intended to 
examine or address more general questions about software and copyright 
protection.

DATES: Written comments must be received no later than February 16, 
2016 at 11:59 p.m. Eastern Time. Written reply comments must be 
received no later than March 18, 2016 at 11:59 p.m. Eastern Time. The 
Office will be announcing one or more public meetings, to take place 
after written comments are received, by separate notice in the future.

ADDRESSES: All comments must be submitted electronically. Specific 
instructions for submitting comments will be posted on the Copyright 
Office Web site at http://www.copyright.gov/policy/software on or 
before February 1, 2016. To meet accessibility standards, all comments 
must be provided in a single file not to exceed six megabytes (MB) in 
one of the following formats: Portable Document File (PDF) format 
containing searchable, accessible text (not an image); Microsoft Word; 
WordPerfect; Rich Text Format (RTF); or ASCII text file format (not a 
scanned document). Both the web form and face of the uploaded comments 
must include the name of the submitter and any organization the 
submitter represents. The Office will post all comments publicly in the 
form that they are received. If electronic submission of comments is 
not feasible, please contact the Office using the contact information 
below for special instructions.

FOR FURTHER INFORMATION CONTACT: Sarang V. Damle, Deputy General 
Counsel, [email protected]; Catherine Rowland, Senior Advisor to the 
Register of Copyrights, [email protected]; or Erik Bertin, Deputy 
Director of Registration Policy and Practice, [email protected]. Each can 
be reached by telephone at (202) 707-8350.

SUPPLEMENTARY INFORMATION: Copyrighted software can be found in a wide 
range of everyday consumer products--from cars, to refrigerators, to 
cellphones, to thermostats, and more. Consumers have benefited greatly 
from this development: Software brings new

[[Page 77669]]

qualities to ordinary products, making them safer, more efficient, and 
easier to use. At the same time, software's ubiquity raises significant 
policy issues across a broad range of subjects, including privacy, 
cybersecurity, and intellectual property rights. These include 
questions about the impact of existing copyright law on innovation and 
consumer uses of everyday products and innovative services that rely on 
such products. In light of these concerns, Senators Charles E. Grassley 
and Patrick Leahy (the Chairman and Ranking Member, respectively, of 
the Senate Committee on the Judiciary) have asked the U.S. Copyright 
Office to ``undertake a comprehensive review of the role of copyright 
in the complex set of relationships at the heart'' of the issues raised 
by the spread of software in everyday products.\1\ The Senators called 
on the Office to seek public input from ``interested industry 
stakeholders, consumer advocacy groups, and relevant federal 
agencies,'' and make appropriate recommendations for legislative or 
other changes.\2\ The report must be completed no later than December 
15, 2016.\3\
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    \1\ Letter from Sen. Charles E. Grassley, Chairman, Senate 
Committee on the Judiciary, and Sen. Patrick Leahy, Ranking Member, 
Senate Committee on the Judiciary, to Maria A. Pallante, Register of 
Copyrights, U.S. Copyright Office, at 1 (Oct. 22, 2015), available 
at http://www.copyright.gov/policy/software.
    \2\ Id. at 2.
    \3\ Id.
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    This study is not the proper forum for issues arising under section 
1201 of the Copyright Act, which addresses the circumvention of 
technological protection measures on copyrighted works. Earlier this 
year, the Register of Copyrights testified that certain aspects of the 
section 1201 anticircumvention provisions of the Digital Millennium 
Copyright Act (``DMCA'') were unanticipated when enacted almost twenty 
years ago, and would benefit from further review. These issues include, 
for example, the application of anticircumvention rules to everyday 
products, as well as their impact on encryption research and security 
testing. If you wish to submit comments about section 1201, please do 
so through the forthcoming section 1201 study, information on which 
will be available shortly at www.copyright.gov.

I. Background

    Copyright law has expressly protected computer programs,\4\ whether 
used in general purpose computers or embedded in everyday consumer 
products, since the enactment of the 1976 Copyright Act (``1976 Act''). 
Though the 1976 Act did not expressly list computer programs as 
copyrightable subject matter, the Act's legislative history makes it 
evident that Congress intended for them to be protected by copyright 
law as literary works.\5\ At the same time, in the 1976 Act, Congress 
recognized that ``the area of computer uses of copyrighted works'' was 
a ``major area [where] the problems are not sufficiently developed for 
a definitive legislative solution.'' \6\ Accordingly, as originally 
enacted, 17 U.S.C. 117 ``preserve[d] the status quo'' as it existed in 
1976 with respect to computer uses,\7\ by providing that copyright 
owners had no ``greater and lesser rights with respect to the use of 
the work in conjunction with automatic systems capable of storing, 
processing, retrieving, or transferring information, or in conjunction 
with any similar device, machine, or process, than those afforded to 
works under the law'' as it existed prior to the effective date of the 
1976 Act.\8\
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    \4\ Although the Copyright Act uses the term ``computer 
program,'' see 17 U.S.C. 101 (definition of ``computer program''), 
the terms ``software'' and ``computer program'' are used 
interchangeably in this notice.
    \5\ See H.R. Rep. No. 94-1476, at 55 (1976); see also National 
Commission on New Technological Uses of Copyrighted Works, Final 
Report of the National Commission on New Technological Uses of 
Copyrighted Works 16 (1978) (``CONTU Report'').
    \6\ H.R. Rep. No. 94-1476, at 55.
    \7\ Id.
    \8\ Public Law 94-553, sec. 117, 90 Stat. 2541, 2565 (1976).
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    Since the 1976 Act's enactment, the scope of copyright protection 
for computer programs has continued to be refined by Congress through 
legislation and by the courts through litigation. At least some of that 
attention has focused on the precise problem presented here: The 
presence of software in everyday products.

A. CONTU Report

    In the mid-1970s, Congress created the National Commission on New 
Technological Uses of Copyrighted Works (``CONTU'') to study and report 
on the complex issues raised by extending copyright protection to 
computer programs.\9\ In its 1978 Report, CONTU recommended that 
Congress continue to protect computer programs under copyright law, 
specifically by amending section 101 of the 1976 Act to include a 
definition of computer programs and by replacing section 117 as enacted 
in the 1976 Act with a new provision providing express limitations on 
the exclusive rights of reproduction and adaptation of computer 
programs under certain conditions.\10\ Congress adopted CONTU's 
legislative recommendations in 1980.\11\
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    \9\ See CONTU Report at 3-4.
    \10\ Id. at 12.
    \11\ See Act of Dec. 12, 1980, Public Law 96-517, sec. 10, 94 
Stat. 3015, 3028-29.
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    While CONTU did not specifically anticipate that software would 
become embedded in everyday products, CONTU did recognize some general 
issues resulting from the fact that computer programs need a machine to 
operate. Specifically, CONTU recognized that the process by which a 
machine operates a computer program necessitates the making of a copy 
of the program and that adaptations are sometimes necessary to make a 
program interoperable with the machine.\12\ CONTU preliminarily 
addressed these issues by including in its recommended revisions to 
section 117 a provision permitting the reproduction or adaptation of a 
computer program when created as an essential step in using the program 
in conjunction with a machine, finding that ``[b]ecause the placement 
of a work into a computer is the preparation of a copy, the law should 
provide that persons in rightful possession of copies of programs be 
able to use them freely without fear of exposure to copyright 
liability.'' \13\ CONTU's recommendations for the new section 117 also 
included a provision permitting the making of copies and adaptations 
for archival purposes.\14\
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    \12\ See CONTU Report at 12-14.
    \13\ Id. at 12-13.
    \14\ Id.
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    At the same time, CONTU foresaw that the issues surrounding 
copyright protection for software would have to be examined again by 
Congress and the Copyright Office:

    [T]he Commission recognizes that the dynamics of computer 
science promise changes in the creation and use of authors' writings 
that cannot be predicted with any certainty. The effects of these 
changes should have the attention of Congress and its appropriate 
agencies to ensure that those who are the responsible policy makers 
maintain an awareness of the changing impact of computer technology 
on both the needs of authors and the role of authors in the 
information age. To that end, the Commission recommends that 
Congress, through the appropriate committees, and the Copyright 
Office, in the course of its administration of copyright 
registrations and other activities, continuously monitor the impact 
of computer applications on the creation of works of authorship.\15\
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    \15\ Id. at 46.

B. Computer Software Rental Amendments Act of 1990

    A decade later, in response to concerns that commercial rental of

[[Page 77670]]

computer programs would encourage illegal copying of such programs, 
Congress passed the Computer Software Rental Amendments Act of 1990 
(``Computer Software Rental Act''), which amended section 109 of the 
Copyright Act to prohibit the rental, lease or lending of a computer 
program for direct or indirect commercial gain unless authorized by the 
copyright owner of the program.\16\ Notably, Congress also expressly 
provided an exception to this prohibition for ``a computer program 
which is embodied in a machine or product and which cannot be copied 
during the ordinary operation or use of the machine or product.'' \17\ 
In doing so, Congress recognized that computer programs can be embedded 
in machines or products and tailored the rental legislation to avoid 
interference with the ordinary use of such products.\18\
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    \16\ See Public Law 101-650, 104 Stat. 5089, 5134-35 (1990); 17 
U.S.C. 109(b)(1)(A).
    \17\ 17 U.S.C. 109(b)(1)(B)(i).
    \18\ See Computer Software Rental Amendments Act (H.R. 2740, 
H.R. 5297, and S. 198): Hearing Before the Subcomm. on Courts, 
Intellectual Prop., and the Admin. of Justice of the H. Comm. on the 
Judiciary, 101st Cong. 15-16 (1990) (statement of Rep. Mike Synar) 
(``Some parties have interpreted the [Computer Software Rental Act] 
as potentially affecting computer programs which may be contained as 
a component of another machine, such as a program which drives a 
mechanized robot or runs a microwave or a household kitchen utensil. 
Such a result was not intended and will be addressed in this 
legislation.'').
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C. DMCA

    Congress revisited the issues surrounding software and copyright 
law with the DMCA.\19\ As particularly relevant here, the DMCA amended 
section 117 of the Copyright Act to permit the reproduction of computer 
programs for the purposes of machine maintenance or repair following a 
court of appeals decision \20\ that cast doubt on the ability of 
independent service organizations to repair computer hardware.\21\ This 
provision foreshadows the more general concerns raised by the spread of 
software in everyday products--namely, that maintaining or repairing a 
software-enabled product often will require copying of the software. 
Section 104 of the DMCA also directed the Office to study the effects 
of the DMCA amendments and the development of electronic commerce and 
associated technology on the operation of sections 109 and 117 of the 
Copyright Act, as well as ``the relationship between existing and 
emergent technology and the operation of sections 109 and 117.'' \22\ 
The Office subsequently published a report detailing its findings and 
recommendations in August 2001 (``Section 104 Report'').\23\
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    \19\ Public Law 105-304, 112 Stat. 2860 (1998).
    \20\ MAI Sys. Corp. v. Peak Computer, 991 F.2d 511 (9th Cir. 
1993).
    \21\ See DMCA, sec. 302, 112 Stat. 2860, 2887 (1998); S. Rep. 
No. 105-190, at 21-22 (1998).
    \22\ DMCA, sec. 104, 112 Stat. 2860, 2876 (1998).
    \23\ See generally U.S. Copyright Office, DMCA Section 104 
Report (2001).
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    The Section 104 Report discussed a number of issues relevant to the 
discussion of software in everyday products. For instance, it addressed 
proposals to add a ``digital first sale'' right to section 109 of the 
Copyright Act to explicitly grant consumers the authority to resell 
works in digital format. Although the Office concluded that no 
legislative changes to section 109 were necessary at the time, it 
recognized that ``[t]he time may come when Congress may wish to 
consider further how to address these concerns.'' \24\ In particular, 
the Office anticipated some of the issues presented here when it 
highlighted ``the operation of the first sale doctrine in the context 
of works tethered to a particular device''--an example of which would 
be software embedded in everyday products--as an issue worthy of 
continued monitoring.\25\ Additionally, the Office noted the concern 
that unilateral contractual provisions could be used to limit 
consumers' ability to invoke exceptions and limitations in copyright 
law. Although the Office concluded that those issues were outside the 
scope of the study, and that ``market forces may well prevent right 
holders from unreasonably limiting consumer privileges,'' it also 
recognized that ``it is possible that at some point in the future a 
case could be made for statutory change.'' \26\
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    \24\ Id. at 96-97.
    \25\ Id. at xvi-xvii.
    \26\ Id. at 162-64.
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D. Developments in Case Law

    In the meantime, courts, too, have weighed in on a number of issues 
concerning copyright protection of software, including 
copyrightability, the application of the fair use doctrine, and 
ownership of software by consumers. In analyzing these issues, however, 
courts have not generally distinguished between software installed on 
general purpose computers and that embedded in everyday products.
    Courts have helped define the scope of copyright protection for 
software and address questions of infringement through application of 
doctrines such as the idea/expression dichotomy (codified in 17 U.S.C. 
102(b)), merger, and sc[egrave]nes [agrave] faire.\27\ The idea/
expression dichotomy, as applied to software, excludes from copyright 
protection the abstract ``methodology or processes adopted by the 
programmer'' in creating the code.\28\ In the context of software, the 
merger doctrine excludes certain otherwise creative expression from 
copyright protection when it is the only way, or one of a limited 
number of ways, to perform a given computing task.\29\ The 
sc[egrave]nes [agrave] faire doctrine has been used to limit or 
eliminate copyright protection for elements of a program that are 
dictated by external factors or by efficiency concerns, such as the 
mechanical specifications of the computer on which the program 
runs.\30\
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    \27\ See, e.g., Lexmark International, Inc. v. Static Control 
Components, Inc., 387 F.3d 522, 534-36 (6th Cir. 2004); Apple 
Computer, Inc. v. Franklin Computer Corp., 714 F.2d 1240, 1252-53 
(3d Cir. 1983); Computer Management Assistance Co. v. DeCastro, 220 
F.3d 396, 400-02 (5th Cir. 2000).
    \28\ H.R. Rep. No. 94-1476, at 9; see also CONTU Report at 22 
(``[C]opyright leads to the result that anyone is free to make a 
computer carry out any unpatented process, but not to misappropriate 
another's writing to do so.'').
    \29\ See CONTU Report at 20 (``[C]opyrighted language may be 
copied without infringing when there is but a limited number of ways 
to express a given idea. . . . In the computer context, this means 
that when specific instructions, even though previously copyrighted, 
are the only and essential means of accomplishing a given task, 
their later use by another will not amount to an infringement.'').
    \30\ See, e.g., Lexmark, 387 F.3d at 535-36 (outlining 
applicability of doctrine to computer programs).
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    The fair use doctrine, codified in 17 U.S.C. 107, is also relevant 
here. Courts have applied the fair use doctrine to permit uses of 
software that ensure interoperability of software with new products and 
devices. For example, in Sega Enterprises Ltd. v. Accolade, Inc., the 
Court of Appeals for the Ninth Circuit held that copying a video game 
console's computer program to decompile and reverse engineer the object 
code to make it interoperable with video games created by the defendant 
was a fair use.\31\ Similarly, in Sony Computer Entertainment, Inc. v. 
Connectix Corp., the court held that reverse engineering the operating 
system of a PlayStation gaming console to develop a computer program 
allowing users to play PlayStation video games on a desktop computer, 
as well as making copies in the course of such reverse engineering, was 
a fair use.\32\
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    \31\ 977 F.2d 1510, 1527-28 (9th Cir. 1992), amended by 1993 
U.S. App. LEXIS 78 (9th Cir. 1993).
    \32\ 203 F.3d 596, 602-08 (9th Cir. 2000).
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    Another important issue courts have tackled involves the scope of 
section 117's limitations on exclusive rights in computer programs. 
Section 117(a) allows copies or adaptations of

[[Page 77671]]

computer programs to be made either ``as an essential step in the 
utilization of the computer program in conjunction with a machine'' or 
for archival purposes, but this provision may only be invoked by ``the 
owner of a copy of a computer program.'' \33\ This raises difficult 
questions regarding whether a consumer owns a copy of software 
installed on a device or machine for purposes of section 117 when 
formal title is lacking or a license purports to impose restrictions on 
the use of the computer program. Courts have provided somewhat 
conflicting guidance regarding this issue, and the application of the 
law can be unclear in many contexts.\34\
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    \33\ 17 U.S.C. 117(a).
    \34\ Compare Krause v. Titleserv, Inc., 402 F.3d 119, 124 (2d 
Cir. 2005), with Vernor v. Autodesk, Inc., 621 F.3d 1102, 1111 (9th 
Cir. 2010).
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E. Recent Legislation

    Issues associated with the spread of copyrighted software in 
everyday products have prompted legislative action in an attempt to 
address some of the copyright issues created by the spread of such 
works.\35\ In the context of section 1201--which, as explained, is the 
subject of a separate Copyright Office study--Congress enacted 
legislation in August 2014 to broaden the regulatory exemption 
permitting the circumvention of technological measures for the purpose 
of connecting wireless telephone handsets to wireless communication 
networks (a process commonly known as ``cellphone unlocking'').\36\
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    \35\ Bills have also been introduced addressing related issues 
outside copyright law stemming from the spread of software in 
everyday products. The Spy Car Act of 2015 would direct the National 
Highway Traffic Safety Administration to conduct a rulemaking and 
issue motor vehicle cybersecurity regulations protecting against 
unauthorized access to electronic systems in vehicles or driving 
data, such as information about a vehicle's location, speed or 
owner, collected by such electronic systems. SPY Car Act of 2015, S. 
1806, 114th Cong. sec. 2 (2015). A discussion draft introduced in 
the Commerce, Manufacturing, and Trade Subcommittee of the Energy & 
Commerce Committee of the House of Representatives would prohibit 
access to electronic control units or critical systems in a motor 
vehicle. A Bill to provide greater transparency, accountability, and 
safety authority to the National Highway Traffic Safety 
Administration, and for other purposes [Discussion Draft], 114th 
Cong. sec. 302 (2015), available at http://docs.house.gov/meetings/IF/IF17/20151021/104070/BILLS-114pih-DiscussionDraftonVehicleandRoadwaySafety.pdf.
    \36\ See Unlocking Consumer Choice and Wireless Competition Act, 
Public Law 113-144, 128 Stat. 1751 (2014).
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    The Unlocking Technology Act of 2015, as most pertinent to this 
study, would amend section 117 of the Copyright Act to permit the 
reproduction or adaptation of ``the software or firmware of a user-
purchased mobile communications device for the sole purpose of . . . 
connect[ing] to a wireless communications network'' if the reproduction 
or adaptation is initiated by or with the consent of the owner of the 
device, the owner is in legal possession of the device, and the owner 
has the consent of the authorized operator of the wireless 
communications network to use the network.\37\ The legislation would 
also limit the prohibition on circumvention in section 1201 of title 17 
to circumstances where circumvention is carried out in order to 
infringe or facilitate the infringement of a copyrighted work, and 
would permit the use of or trafficking in circumvention devices unless 
the intent of such use or trafficking is to infringe or facilitate 
infringement.\38\
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    \37\ Unlocking Technology Act, H.R. 1587, 114th Cong. sec. 3 
(2015).
    \38\ Id. sec. 2.
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    In addition, the You Own Devices Act (``YODA'') would amend section 
109 of the Copyright Act to allow the transfer of ownership of a copy 
of a computer program embedded on a machine or other product ``if [the] 
computer program enables any part of [that] machine or other product to 
operate,'' as well as any right to receive software updates or security 
patches from the manufacturer.\39\ This right of transfer could not be 
waived by any contractual agreement.\40\ In addition, the original 
owner of the device would be prohibited from retaining an unauthorized 
copy of the computer program after transferring the device and the 
computer program to another person.\41\
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    \39\ YODA, H.R. 862, 114th Cong. sec. 2 (2015).
    \40\ Id.
    \41\ Id.
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F. Relationship to Questions About Section 1201

    Some issues related to software embedded in everyday products have 
come to the forefront in recent years through the 1201 rulemaking 
process. As the Copyright Office has frequently noted, the 1201 
rulemaking can serve as a barometer for larger public policy questions, 
including issues that may merit or would require legislative change. 
The public should not submit concerns about section 1201 through this 
software study, but rather through the Copyright Office's forthcoming 
study on section 1201, information about which will be available 
shortly at http://www.copyright.gov/.

II. Subjects of Inquiry

    In response to the letter from Senators Grassley and Leahy, the 
Office is seeking public comment on the following five topics. A party 
choosing to respond to this Notice of Inquiry need not address every 
subject, but the Office requests that responding parties clearly 
identify and separately address each subject for which a response is 
submitted.
    1. The provisions of the copyright law that are implicated by the 
ubiquity of copyrighted software in everyday products;
    2. Whether, and to what extent, the design, distribution, and 
legitimate uses of products are being enabled and/or frustrated by the 
application of existing copyright law to software in everyday products;
    3. Whether, and to what extent, innovative services are being 
enabled and/or frustrated by the application of existing copyright law 
to software in everyday products;
    4. Whether, and to what extent, legitimate interests or business 
models for copyright owners and users could be undermined or improved 
by changes to the copyright law in this area; and
    5. Key issues in how the copyright law intersects with other areas 
of law in establishing how products that rely on software to function 
can be lawfully used.
    When addressing these topics, respondents should consider the 
following specific issues:
    1. Whether copyright law should distinguish between software 
embedded in ``everyday products'' and other types of software, and, if 
so, how such a distinction might be drawn in an administrable manner.
    a. Whether ``everyday products'' can be distinguished from other 
products that contain software, such as general purpose computers--
essentially how to define ``everyday products.''
    b. If distinguishing between software embedded in ``everyday 
products'' and other types of software is impracticable, whether there 
are alternative ways the Office can distinguish between categories of 
software.
    2. The rationale and proper scope of copyright protection for 
software embedded in everyday products, including the extent to which 
copyright infringement is a concern with respect to such software.
    3. The need to enable interoperability with software-embedded 
devices, including specific examples of ways in which the law 
frustrates or enables such interoperability.
    4. Whether current limitations on and exceptions to copyright 
protection

[[Page 77672]]

adequately address issues concerning software embedded in everyday 
products, or whether amendments or clarifications would be useful. 
Specific areas of interest include:
    a. The idea/expression dichotomy (codified in 17 U.S.C. 102(b))
    b. The merger doctrine
    c. The sc[egrave]nes [agrave] faire doctrine
    d. Fair use (codified in 17 U.S.C. 107)
    e. The first-sale doctrine (codified in 17 U.S.C. 109)
    f. Statutory limitations on exclusive rights in computer programs 
(codified in 17 U.S.C. 117)
    5. The state of contract law vis-[agrave]-vis software embedded in 
everyday products, and how contracts such as end user license 
agreements impact investment in and the dissemination and use of 
everyday products, including whether any legislative action in this 
area is needed.
    6. Any additional relevant issues not raised above.

    Dated: December 9, 2015.
Maria A. Pallante,
Register of Copyrights, U.S. Copyright Office.
[FR Doc. 2015-31411 Filed 12-14-15; 8:45 am]
 BILLING CODE 1410-30-P