September 21, 2018
The NPPA, as part of a Coalition of Visual Artists, submitted comments to the U.S. Copyright Office in opposition to proposed increases in copyright registration fees.
Those comments “strongly objected to the proposed across the board fee increases and more specifically to the proposed increase in copyright registration fees for group registration of unpublished photographs (GRUPH) and group registration of published photographs (GRPPH) from $55 to $100.”
The coalition believes that the proposed 82% fee increase for group registrations along with the February 2018 rule limiting the number of images that may be submitted in a group registration for published and unpublished images to 750 photographs creates a crippling “double whammy” for many photographers.
While “photographers support and need the copyright system to help give them some measure of protection from unauthorized use of their images, the complexities and expense of registration already keep most photographers from registering their images. Increasing fees 82% will only exacerbate that problem and act as a disincentive to registration.”
The comment also included anecdotal evidence and empirical data from a recent survey and noted, “far too many small creators already see copyright as a hollow right without a remedy, and a dramatic registration fee increase will only reinforce their perception that registration brings an unbearable cost without any real benefit.”
The coalition requested that “the Copyright Office not let the ends justify the means in burdening small creators with the cost of an inappropriate and excessive copyright registration fee increase without the further considerations” and urged it “to pursue other ways of reducing costs and increasing revenue as they outlined.”
The Coalition of Visual Artists includes the American Photographic Artists, American Society for Collective Rights Licensing, American Society of Media Photographers, Digital Media Licensing Association, Eugene Mopsik, Graphic Artists Guild, National, Press Photographers Association, North American Nature Photography Association. Professional Photographers of America, Shaftel & Schmelzer.
To view the entire document, click here.
UPDATE: Comments of other organizations, companies, and individuals, including several NPPA members, can be found at this link.