ImageRights Submits Comments to the U.S. Copyright Office on Proposed Fee Increases
ImageRights recently submitted formal comments to the U.S. Copyright Office (USCO) in response to its Notice of Proposed Rulemaking (NPRM) on Copyright Office fees. The proposed schedule would raise fees by an average of 43% across the board, including a 55% increase for group registration of photographs (from $55 to $85) and a 53% increase for group registration of two-dimensional artwork (from $85 to $130).In our comments, we stated that we cannot support the proposed fee increases. The 55% and 53% increases are well above the median CPI inflation since 2020 of approximately 23% and well above the projected three-year forward inflation of approximately 10% cited in the NPRM. We asked the USCO to:
1. Defer the proposed increases until the Enterprise Copyright System (ECS) for registration is complete (currently scheduled for 2028);
2. Give explicit weight to per-registration economics, not just per-work figures, when evaluating fee impact; and
3. Incorporate a price elasticity evaluation into any revised fee proposal, given the documented decline in registrations since 2019.
USCO Registration Through ImageRights
Since 2009, ImageRights has registered almost 2 million images with the U.S. Copyright Office on behalf of its photographers, illustrators, and digital artists. Timely registration is the single most important step a creator can take to protect their work, as it unlocks the right to recover statutory damages and attorneys' fees in cases of infringement.
Learn more about our USCO registration service at imagerights.com/copyright
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