Our reply comments to the Copyright Office regarding the proposed rulemaking on section 115 compulsory licensing have been posted to the Copyright Office's website and can be found here.
In our reply comments we reiterated our previous argument that the proposed changes would chill innovation in digital technology and we echoed certain concepts and proposed solutions submitted by other public interest commenters who have participated in the proceedings. The Copyright Office is slated to make a decision on Thursday.
To point out just one example of the effect such proposed rulemaking might have on the industry and innovation; today Appleinsider revealed that Apple has considered shutting down Itunes if they are forced to pay double royalties for each download as a result of the proposed rulemaking because they are already teetering on the brink of unoprofitability as it is. If Apple can't afford it, then who can?