The Institute of Intellectual Property and Social Justice (“IIPSJ”) is submitting this comment letter regarding diversity and inclusion to the U.S. Copyright Office (“COLC”) to address significant social justice concerns in connection with the selection of a Music Licensing Collective pursuant to the Music Modernization Act (“MMA”) by the Register of Copyrights.

From its inception, IIPSJ has regularly contributed to the public discourse on IP social policy and legal developments, through testimony and submissions to governmental bodies and judicial proceedings, presentations at practitioner and academic IP conferences, and participation in online fora. Indeed, earlier this year IIPSJ submitted to Congress both formal comments and also a letter on behalf of intellectual property law and other scholars to support passage of the Compensating Legacy Artists for their Songs, Service, and Important Contributions to Society (CLASSICS) Act and the Music Modernization Act (MMA), and otherwise undertook a public campaign in support of these legislative bills.

We submit that COLC’s request that a “proposed 2 MLC address how it interprets and satisfies [the] endorsement criteria, including an explanation of how the proposed MLC has calculated and documented the endorsement and substantial support of the requisite number of copyright owners” must include how the proposed MLC will represent the diversity in the American music industry and copyright ownership.