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Comments delivered by the FSF to the Copyright Office

by John Sullivan Contributions Published on Aug 25, 2005 02:52 PM
Thanks to everyone who took the time to write and send a comment. With the help of DC-based Public Knowledge, we were able to hand-deliver the printed comments to the Copyright Office on Monday, August 22, 2005. A sampling of the comments we received is included below, in no particular order.


Please be assured that limiting access to users of Internet Explorer
would exclude many scientists and innovators from your website. I
myself am an example. You can read my NIH biosketch in order to see
that I am the very type of person that would patent some work.

I will never use Internet Explorer, because it is not free software,
and because Microsoft has proven hostile to innovation and software
freedom. Please consider adhering to public standards for the WWW,
and not proprietary software standards, which are inimical to the
"promotion of arts and sciences".

Michael L. Love Ph.D
Department of Biophysics and Biophysical Chemistry
School of Medicine
Johns Hopkins University


To the Copyright Office --

I object to the proposed federal rule that preregistration of
copyright be supported only through the proprietary Microsoft browser
Internet Explorer. As a democracy, interacting with the government
with software that is freely available to the public should be a
priority -- or at the very least, on an equal footing with proprietary

There are many free -- as in freedom -- browsers available for all
platforms, such as Mozilla Firefox. There is no reason to restrict an
official government site to a certain browser; it may benefit the
manufacturer of that browser, but it will deny access to the many,
many citizens who use free browsers.

Please do not adopt this rule.


Karl Berry
Bandon, OR


This is to register my objection to the Copyright Office requiring the
use of Internet Explorer (IE) for the electronic submission of
copyrights. I use the GNU/Linux operating system exclusively and IE
is not available for such systems. In order to electronically submit
a copyright request, I would be forced to find and use a publicly
available computer and risk exposing my personal information to anyone
else using that public computer. This is on top of the fact that IE
is itself notoriously insecure and virus prone. Moreover, it requires
the use of a proprietary operating system. Please consider the many
good alternative browsers that will run on any operating system and
that use free software.

Thank you,

Dr. Michael Gass
Collegeville, MN


Comment on the Copyright Office's Notice of Proposed Rulemaking

I read with dismay that the Copyright Office proposes to make it
necessary to use Microsoft Internet Explorer on Windows to use the
electronic pre-registration service. Further research reveals that
this is a limitation imposed by the version of the Siebel CRM system
currently used. Although I am sympathetic to the Siebel position that
elaborate regression testing is required to claim support for a
particular OS/browser combination, and to the Copyright Office's
desire to avoid changing versions until necessary, the result is

In a world where well-defined, open standards exist for the web,
standards that have been implemented by dozens of browsers and web
servers, there is no excuse for requiring a citizen to buy and use
specific products from a single large company to make use of
government services. After ten years of mass adoption of the web, how
can this question even be open to debate?

There are times when a single browser requirement makes sense - for
example, when a company wishes to deploy inward-facing services for
its own employees and partners. And of course a company may choose to
do this for customer-facing services, although most that have gone
done this road have realized and corrected their mistake. But for the
government to willfully exclude citizens from access to services on
this basis is entirely unacceptable.

Steven L. Salkin, Jr.
Roswell, GA


Subj: Internet Explorer restriction for online copyright registration

We protest the proposal to initially allow only users of Internet
Explorer (IE) to register copyrights online.

Though Internet Explorer has a large user population and is widely
available, it is not supported by all major computer platforms (e.g.:
Linux), and strictly speaking, is not a no cost application. It also
is not open-source software, which leaves users at the mercy of
Microsoft with respect to upgrades.

The proposal to initially support only Internet Explorer excludes
users of non-Windows/non-Apple products from the full spectrum of
services provided by the Copyright Office. It also puts the Copyright
Office in the unusual and inappropriate position of being a marketing
agent for Microsoft, an excellent firm but one that probably does not
need the US government to market its products.

If the Copyright Office feels that it only has resources to support
one browser, then a freely-available, open-source browser such as
Firefox would be a better choice.

Thank you.
ORIMP, Inc., Cupertino, CA


At this Web address:

A proposed policy with title "Preregistration of Certain Unpublished
Copyright Claims" asks if whether or not we would have any problem if
we were required to use the Microsoft Internet Explorer browser for
preregistering a work.

Requiring the use of Internet Explorer is not-appropriate for the
open-source world that we live in. I commonly use UNIX and LINUX
machines where an Internet Explorer browser is not available. My
personal preference on the 3 Windows machines that I utilize is
FireFox. The FireFox browser has been noted as being safer to use,
smaller in terms of memory usage, and better human factors.

Designing a website to only work with Internet Explorer is a decision
that does not need to be done. I commonly utilize websites that work
equally well with a variety of browsers - with no loss of the user
experience. In fact - I was using FireFox when I saw the request for

Curtis Keller
Houston, Tx


To The United States Copyright Office,

Subj: "Today's notice seeks information as to whether persons filing
the electronic-only preregistration form prescribed by the Copyright
Office will experience difficulties if it is necessary to use
Microsoft's Internet Explorer web browser in order to preregister a
work. "

Difficulties will be experienced not only by the users of this form
but by the general public also. Microsoft's Internet Explorer is a
proprietory software that is not available to all computer users on
all major operating systems. To specify the required use of only one
web browser, and a proprietory one, creates a monopoly situation where
it is not necessary. There are many web browsers that can perform the
function of form entry, requiring computer users touse only one web
browser is akin to to requiring all applicants to come to your office
in one make of car or to fill out the form in only one brand of ball
point pen. It would bring difficulties to other web browser companies
and developers who would be forced out of the market by government
rule. It would cause difficulties for anyone who wishes to fill out
the electronic form in that they would have to purchase or obtain this
specific proprietary software and figure out how to make it run on
their particular operating system. Microsoft Internet Explorer is
known to be a problem in that it has a history of being open to
attacks of viruses which cause much damage and problems to computers
as well as difficulties to their users/owners. To require by law the
monopolistic sole use of one browser only is wrong from the start and
causes vast difficulties throughout the IT industry and as a precedent
throughout the freedoms of the country. Using Microsoft as the
monopolistic chosen favorite son is an even greater wrong as
controlling and monopolising their field is a long term strategy with
them that goes against the principles of free enterprise. That the
Government should want to sponsor such monopolistic and detrimental
practices is again a greater wrong that will bring with it great
difficulties to every citizen of the country. The freedom for anyone
to equally enter and compete in the marketplace is a very fundamental
principle of our free nation.
Yours in Truth,

Mark Chasan


To whom it may concern,

When a government agency enforces the use of a proprietary product of
a profit making company, it is doing so by undermining the freedom as
well as the well being of the citizens of the United States of

By enforcing an insecure, unreliable, and proprietary product for the
use of serving the interest of the business community as well as the
general public, the U.S.C.O. is supporting a company which objectives
are to make a profit and suppress the freedom of computer users around
the world.

The U.S.C.O. knowingly or unknowingly is setting an appalling paradigm
to other government agencies not just in the U.S. but also around the
world. Many governments around the world big or small are looking up
to the U.S. for guidance and example. In doing so many are carelessly
assuming that U.S. government agencies knows best.

By enforcing the use of any proprietary product the U.S.C.O. is
setting an ill example to other government agencies around the world,
indirectly changing their perceptions and give reason to implement the
same poorly thought of decisions. Government agencies will then by
example of the U.S.C.O. suppress the people�s basic right to freedom.

It is then with great discontent that I appeal to you not to make use
of a proprietary solution, but to serve in the best interest of the
general public and support and make use of a free, libr� and an open
standard solutions.

Jaco du Preez Centurion, South Africa


Requiring the users of film-editing tools or sound-editing tools (who
generally have historically worked on Macintosh computers) to use an
application which is only being usefully updated on the Microsoft
Windows platform to utilize a service of the US Government is
counterproductive at best. There are standards which can be coded to,
and your web designers and programmers need to start referencing those
standards, rather than be shock-and-awed by "hey, look what IE can

Requiring MSIE as the only manner in which people can pre-register is
unwarranted, and will cause undue hardship.


Kyle A Hamilton
Tucson, AZ


To: *Copyright Office, Library of Congress*

RE: Preregistration of Certain Unpublished Copyright Claims ACTION:
Supplemental notice of proposed rulemaking

37 CFR Part 202 [Docket No. RM 2005-9]

As a GNU/Linux user and proponent of free software, and also an Apple
Macintosh user, I will not easily be able to use the initial
pre-registration form. When using GNU/Linux, Internet Explorer is not
available for use. When using my Macintosh, I will have to use
Internet Explorer for Macintosh, a program that has not been supported
by Microsoft for over two years, and may not work with the form
because it is not running on a Window's operating system. I also
wonder if this IE only form will meet the accessibility requirements
of the Americans with Disabilities Act.

Most vexing to me as a U.S. taxpayer, is that a system is being
developed which will cost more to develop, will cost more to maintain,
and potentially be more error prone because it will apparently use at
least two different implementations to achieve the same result once
other browsers are supported. I find this unacceptable. If well
established web and Internet standards are used, one system which
handles all browsers--from the text based Lynx browser to the latest
gui browser of choice--can be created which is accessible and secure
for all users, and will be less expensive to maintain.


Roan Horning
Baltimore, MD



At this Web address:

I read a proposed policy with title "Preregistration of Certain
Unpublished Copyright Claims" which asks the public to inform you
whether or not we would have any problem if we were required to use
the Microsoft Internet Explorer browser for preregistering a work.

Microsoft Internet Explorer uses proprietary technology, such as
ActiveX, which other Web browsers usually do not support. As a result,
I have great difficulty navigating websites that use ActiveX. I know
that it is possible to design a website accessible with any modern Web
browser, by using Web standards such as XHTML and CSS, and - whenever
interactivity is needed - ECMAScript and Java applets (which can run
on most operating systems). Requiring users to use a particular Web
browser causes disruption, especially for Apple Macintosh and
GNU/Linux or BSD operating systems users, who often have no access to
Microsoft Windows and may have never used Microsoft Internet Explorer
(which only runs on Microsoft Windows) before.

Please consider the difficulties of non-Microsoft operating system
users and try to provide a standards-oriented Web design, which would
make their life much easier.

Thank you,

Jarod Arney
South Evansville, IN


To whom it may concern:

To require the user of a public service provided by an office of the
government to use software which requires the purchase of a licence
limits the availability of such a service to everyone.

The role of a public service is to provide access to particular
services for citizens of a country. To facilitate the public, no
government should limit the capabilities of their systems to one
standard, regardless of whether it is the majority system in use.

In other words, having an Internet Explorer only service is the
equivalent of having 3 flights of steps and no wheelchair ramp into
your offices. It takes away a person's ability and freedom to exercise
use of the service.

Even suggesting and implementing a service and stating access for
other systems in the future does not guarantee a timeline or even
ensure that any plan (if any) will ever be executed.

Use of an open standard will ensure that every person with a computer
will be able to use your service, including but not limited to those
using Internet Explorer.


Thom Lanigan
Irish Computer Society Member



At this Web address: I read a proposed
policy with title "Preregistration of Certain Unpublished Copyright
Claims"; which asks the public to inform you whether or not we would
have any problem if we were required to use the Microsoft Internet
Explorer browser for preregistering a work.

Below you can read my personal opinion and feedback on this issue.

All the computers in my house run a variant of GNU/Linux. By using
free software to power my personal computers, I not only save money,
but I also benefit from an increase in security. Additionally, I find
software to be more flexible to my needs, more stable, and generally

Unfortunately, Microsoft has chosen not to allow Internet Explorer to
be ported to GNU/Linux platforms. Instead, I generally use Opera 8.01
running on Mandrake 10 to browse the web. My alternative computer
uses Firefox on a Fedora Core 3 machine. As both these browsers are
W3C-compliant, I find that I can visit virtually every web site on the
Internet without problems.

Microsoft has chosen to include support for additional non-standards
compliant extensions such as ActiveX. These non-standard extensions
sometimes prevent me from viewing specific websites. Although it
occurs rarely, it is especially annoying because Microsoft will not
allow competitors to implement ActiveX extensions. This is an abuse
of a monopoly power, because Microsoft is requiring that consumers
purchase not only a browser, but an entire operating system, merely to
visit a web site. Since Microsoft has chosen not to implement free
software algorithms for utilizing common GNU/Linux file systems,
migrating to a Microsoft-based operating system entails far more cost
than the software price -- which can run into over a thousand dollars
for a home network the size of mine.

Given these facts, I must protest the proposed rule. Should the
Copyright Office require ownership of a suite of Microsoft products in
order to pre-register a copyright, I will not pre-register online. As
a published author, this could entail additional cost and effort on my
part, but it will entail less effort than migrating my home network.

Please consider these facts when making your decision,

James Brokaw
Westminster, MD


Dear Sir or Madam,

I find it unacceptable that Internet Explorer be required for
uploading information to any Federal agency. Browsers based on open
standards, such as Firefox, Opera, Netscape and Mozilla, should be
supported at the same time as IE.

Kimbo Mundy
Albuquerque, NM


To Whom It May Concern:

I am a computer technician and web developer. In the past few years,
most of the computer repair calls that I have received have been about
spy/ad-ware. Besides teaching some correct web etiquette to these
customers, I also suggest that they use Firefox as it has a better
security history as its bugs are fixed quickly. Most do take my
suggestion and I have inadvertently converted many into loyal Firefox
fans. Some have told me they will never use Internet Explorer
again. Now I'm not going to presume that south Louisiana is a
microcosm displaying the behaviors of all Americans, but what if in
this instance it is? How many users would the Copyright Office be
unable to communicate with if it were to pursue an IE-only website?

My worry is much bigger than lack of communication, though. Forcing US
government website visitors to use only Internet Explorer will only
encourage a browser monopoly in favor of Microsoft by effectively
nullifying all competition. Why do I say this? The answer is simply
that I listen to my clients. Most people will not run two browsers on
there computer if they can use one for everything. While most of my
clients say they prefer Firefox, many have stated that they didn't
like that some sites have to be viewed with Internet Explorer. The
reason given most is because it made them stop what they were doing
only to switch browsers. Knowing this, the only conclusion that I can
draw is that if more sites become Internet Explorer only users will
give up a preferred browser (like Firefox, Opera, etc) for one that
doesn't cut their productivity (Internet Explorer).

Thank you,

Jeremy Knight


Words cannot express. The thought that these buzzards should require
use of an Internet tool condemned by their own Department of Homeland
Security boggles the mind and beats everything.

It is also an indication of how poorly software and technical
engineers work within that organisation.



Dear U.S. Copyright Office,

At this Web address:

I read a proposed policy with title "Preregistration of Certain
Unpublished Copyright Claims" which asks the public to inform you
whether or not we would have any problem if we were required to use
the Microsoft Internet Explorer browser for preregistering a work.

Below you can read my personal opinion and feedback on this issue.

I have no access to Microsoft Internet Explorer as I do not use the
Windows operating system. Instead, I use the Novell's SUSE Linux
operating system, which ships with the following Web browsers:
Konqueror, Mozilla Suite, Mozilla Firefox, Galleon, Epiphany, Opera,
Links, and Lynx. These are the most common Web browsers in operating
systems based on GNU/Linux, and I personally use Mozilla Firefox,
which is compatible with most Web standards set by W3C, including

Microsoft Internet Explorer uses proprietary technology, such as
ActiveX, which other Web browsers usually do not support. As a result,
I have great difficulty navigating websites that use ActiveX.

As a an employee of a major software company, I know that it is
possible to design a website accessible with any modern Web browser,
by using Web standards such as XHTML and CSS, and - whenever
interactivity is needed - ECMAScript and Java applets (which can run
on most operating systems). In fact, I've found that all of the major
websites that I visit have done so in the last year.

Requiring users to use a particular Web browser causes disruption and
restricts access, especially for Apple Macintosh and GNU/Linux or BSD
operating systems users, who often have no access to Microsoft Windows
or Internet Explorer (which only runs on Microsoft Windows). Such is
particularly the case for a large portion (if not a majority) of
engineers who work solely on Unix and Linux platforms. This is of
particular concern in my organization where such is the case for the
thousands of software engineers employed here.

Please consider the challenges the proposed change will present to
users of non-Microsoft operating systems and try to provide a
standards-oriented Web design.

Robert Todd Cunningham
Provo, UT


This proposal is absurd. Internet Explorer has a deplorable security
record. There's no reason to lock people into a single web browser -
and certainly not one that is not available for all users/systems and
leaks like a sieve.

Charles Finn
Oceanside, CA


To Whom It May Concern:

This letter is in regard to your plan to limit compatibility with your
web site to users of Microsoft Internet Explorer.

I am a Macintosh user, and find the suggestion more than burdensome.
Microsoft has stopped developing Internet Explorer for Macintosh, and
as a result I would be unable to use the web page. Furthermore, as
Microsoft itself has indicated, its browser does not follow industry-
wide standards for browsers, nor will the version of Microsoft
Internet Explorer to be issued with the forthcoming Microsoft Vista
operating system support those standards. Other issues are key as
well: Microsoft Internet Explorer is not the most secure browser, for
instance. There is also the fine irony that the copyright office is
furthering a monopolistic approach to access.

At the least, I would urge you to make your site compatible with
industry standards, and therefore not to restrict compatibility to a
browser that does not meet those standards.

Alberto Cacicedo


I have access to Microsoft Internet Explorer but choose to use the
Mozilla Firefox browser, even on PCs, because of its significant
safety over Microsoft Internetx Explorer. I have had many instances
where Internet Explorer allowed unwanted software to be installed on
my computer. I am a graduate of Columbia University with a Computer
Science degree and currently a Senior Technical Project Manager at a
Fortune 100 firm and we use Firefox more and more because of its
security AND because so many Internet users are adopting it as for the
same reasons. Firefox and other browser are also strict users Web
standards set by W3C, including XHTML and CSS, which IE does not
adhere to in many instances.

Microsoft Internet Explorer uses proprietary technology, such as
ActiveX, which other Web browsers usually do not support.

As a Computer Science graduate, I know that it is possible to design a
website accessible with any modern Web browser, by using Web standards
such as XHTML and CSS, and - whenever interactivity is needed -
ECMAScript and Java applets (which can run on most operating systems).

Requiring users to use a particular Web browser causes disruption,
especially for some PC users (growing rapidly),Apple Macintosh and
GNU/Linux or BSD operating systems users who may not use (or be able
to use) Microsoft Internet Explorer.

Please consider the difficulties of non-Microsoft operating system
users and try to provide a standards-oriented Web design, which would
make their life much easier.

Thank you,

Simon Metz
Brooklyn NY


To whom it may concern,

I am writing in response to your request for comments to the Notice of
Proposed Rulemaking. It is my understanding from reading the proposal
that you intend to require Microsoft Internet Explorer in order to
access the electronic preregistration form at the Copyright Office. I
must strongly discourage you from such an action for many reasons.
First, many users who do not use the Windows operating system, such as
Mac OS X, Unix, or GNU/Linux, do not have access to Internet Explorer.
Second, Internet Explorer is responsible for many of the virus and
adware problems affecting computers today. Lastly, Internet Explorer
has very poor adherence to web standards. Web standards promote the
growth of the internet. As a government agency, you should be
promoting access to all and encouraging the use of web standards. By
doing so you eliminate access problems and encourage standards

Thank you for the opportunity to voice my concerns,

Vince Chmielewski
Ypsilanti, MI


I use Mozilla Firefox for accessing the Web, not MS Internet Explorer.

I would expect my government not to exclude me from access to
governement services, including registration of copyrights, simply
because I use the second-most-common browser.

Daniel Strome
Madison, Wisconsin


1. If our federal government is going to waste taxpayer time and money
in the pursuit of busting the perceived monopoly of MSFT's Windows and
IE, then why turn around and support that same perceived monopoly?
This is absolutely ridiculous.

2. If an arm of the federal government is going to initiate a system
that supports only one browser, why choose the one browser that has
the worst track record, with regard to security and quality.

3. In the digital age, one of the most important considerations for
any digital system that a government fields is security. It is the
goal of every hacker to break into a MSFT system. Using a more simply
coded, non-integrated web browser (i.e. Firefox or Opera) that still
supports all of the encryption needs will provide a great deal more



I read about USCO intentions and it made me angry. After USCO
rejected Apple's iPod interface patent, it made me think, maybe
Microsoft's 3000 patent quota is a way to funnel money to USCO.

All three issues mentioned here are ridicules.

1. IE is not the only browser in the world, if you don't want to write
multiple page versions, do not use features that are MS specific.

2. Apple used this kind of interface since OS X and NeXT had it way
before. And why do we patent ideas if they are not backed up by
actual working product?

3. Patenting is not a race, you cannot set a quota for how many
patents you going to apply for. MS intention is to patent as many
stupid, small, obvious things that normal people would never think of
patenting, so that MS can sue and crash anybody that tries to invent

Where is our government? In Iraq?


angry computer user that can't stand working with MS products.


To whom it may concern,

In the web development world, professionals create web applications
that will work for the widest possible audience. By developing a
Copyright Office interface to the public that will not work for a
significant and growing number of citizens who use browsers other than
Internet Explorer (IE), the Copyright Office is sending a clear
message to citizens who use browsers other than IE: �Sorry, you�re a
minority of users, therefore you�re not important.�

If the developers of this web application suggest that the number of
citizens using browsers other than IE is insignificant, I�m afraid
that their data are fatally flawed. Check their facts; they are
selling you a product that won�t work for all the people who will want
to use it.

By effectively turning away large numbers of citizens who want to use
this service, the agency will treat them like second-class
citizens. This is unconscionable.

Only an amateur would build a web app that�s browser-specific and
later have to back-engineer for it to work for the rest of the
audience or market. And since no timeline for this future
functionality has been announced, the public must assume that it is a
low priority. What happens, then, if a budget constraint cuts it
altogether? The public�s saddled with a tool that many can�t use.

Mark Bult
web development and usability expert


I do not have any machines that us IE because it is expensive and
insecure. I am against the rule that US citizens be forced to use it
to access government resources.

Mike Weaver
Arlington, Va.


As Microsoft's Internet Explorer (MS IE) web browser product is
well-known to have a long and sordid history of very significant
security flaws (see, for instance,, and as it is
available only on Microsoft Windows (or in limited form on the Apple
Mac), it is clearly a completely unsuitable and unacceptable choice to
be the only browser supported for a particular use - especially a use
so important as the pre-registration of copyright claims. Even an
individual or organization who could afford the financial cost of
using MS IE (due to the cost of the Windows license needed to run it)
would be unwise to actually use a web browser so likely to cause the
user's computer to be hacked, infested, trojaned, or otherwise
compromised. Further, for reasons of cost, support burden,
philosophy, and others, an increasing number of individuals and both
large and small corporations and other organizations (all of which are
eligible to pre-register copyright claims) are choosing to use
non-Windows computers, on which MS IE is not available at any price.

Therefore, requiring the use of MS IE for any purpose, for any amount
of time (never mind for an important purpose such as this, and for an
unspecified period of time), is entirely inappropriate and
unacceptable. It would be far more wise to select for initial
deployment a browser, such as Mozilla or Firefox, which is freely
available on nearly all computers. If it is impractical or too costly
to support multiple browsers at initial deployment, then by all means
support only one at the start - but select one that everyone can use

Christopher S. A. MacGregor
Seattle, WA


My comment directly addresses the following item in the governments
text calling for comments. "Therefore, this notice seeks information
whether any potential preregistration filers would have difficulties
using Internet Explorer (version 5.1 or higher) to file
preregistration claims, and if so, why".

1. Having to purchase software from and support a company that has
been prosecuted by the US government for anti-trust and monopolistic
practices, should for obvious reasons never be a requirement for
access to government services.

2. The requirement for IE explorer would represent a substantial
burden for me as I have no Microsoft software installed on ANY
computers which I would use to perform the preregistration
process. Having to purchase and install a Microsoft operating system
on my computers is just not an option.

3. To answer the question of "Why" I would not be able to use IE
explorer is very simple. I do not own or intend to pay Microsoft in
order to gain access to government services. This is a blatant
endorsement from the government for Microsoft software. This is a very
bad idea and would set a precedent that is simply unacceptable.

Potential Filer

Bob Bischan
St. Louis, Mo


Regarding he Federal Register entry from August 4, 2005:

[Federal Register: August 4, 2005 (Volume 70, Number 149)] [Proposed
Rules] [Page 44878-44879]

Titled: Preregistration of Certain Unpublished Copyright Claims

I commend the Copyright Office for taking steps to permit
electronic-only submission of pre-registration forms for copyright
claims. This is a step forward in our "digital society" and will help
streamline processing of such claims.

I wish to make it clear that I oppose the requirement of using a
single piece of software, namely Internet Explorer (IE), for the
purpose of pre-registering copyright claims. Doing so would impose
difficulties on the users of computers not running the Windows or
Macintosh operating system, as IE is not available for these platforms
(see for an example).
Moreover, it is my understanding that IE is not being developed for
the Macintosh platform any longer, which puts unnecessary difficulty
on Macintosh users, as they would be forced to use older, possibly
insecure, versions of IE.

Also, as IE is the product of a single company, namely Microsoft, this
requirement would unduly favor that company by excluding competing
products from the pre-registration process. Such an exclusion is not
good policy for a democratic government and, in fact, should be
astutely avoided.

As a System Administrator and sometime web developer, I know there is
no technical reason why such a pre-registration form must require a
particular browser, e.g. Internet Explorer. With no more use of
resources (developer time) than an IE-only solution, and no loss in
security, this form could be made accessible to any reasonably
standards-compliant browser, including IE. In terms of development
effort, creating an IE-only solution, then developing solutions for
other browsers later would be more resource-intensive and most likely
more bug-prone. It is better to develop the general-case solution
first and be done.

Please feel free to contact me should you wish my input on possible
solutions for the upcoming pre-registration form.

Charles D. Theobald, Jr.
Eugene, OR


Dear Folks at the Patient Office

There are well known security issues that pervade Microsoft's Internet
Explorer as well as lack of availability on Macintosh
systems. Microsoft has stated that there will be no further
development of browser software for the Macintosh.

These two issues combine to seriously restrict access to your site and
as a public agency the widest access must be assured.

Please do not restrict browsers. Instead simply support and enforce
use of Internet standard means and methods as endorsed by W3C and
other organizations.

Thank you.

Tim Weaver
San Francisco


To Whom It May Concern,

I am a user of Knoppix, a free software GNU/Linux distribution.
Internet Explorer is not available on this operating system. Firefox,
Mozilla, Epiphany and Konqueror are (among others).

I have been using the Internet since 1990, and programming code for
web broswers since 1994. I have never once written a single line of
code that was dependent on functionality exclusive to any one browser
(and don't intend to).

There is no rational reason why the software you are choosing to
implement could not support at least Firefox, and really, it should be
completely agnostic as to the operating system and browser being used
- if a browser is compliant with a specified set of open and widely
agreed upon standards, then it should be acceptable to use that

If this means your third party vendor has to exert some effort to
make their software more compatible, then they should be required to
do that... even better, you should be implementing free software
running on GNU/Linux, not commercial and proprietary code for which
you do not have access to the source or the legal right to modify and
change it as you see necessary.

Thomas Leavitt
Santa Cruz, CA

P.S. and change your ridiculous requirements for submitting
comments... it is 2005, not 1955!


Requiring Internet Explorer to access copyright office services is
like requiring people to drive city streets only in cars without door
locks or ignition keys.

Internet Explorer is the most vulnerable browser available. I gave up
using it long ago because of its susceptibility to spyware and virus

David Clifton
Boulder Colorado


In re: 37 CFR Part 202 [Docket No. RM 2005-9] "Preregistration of
Certain Unpublished Copyright Claims" Copyright Office, Library of

RFC> Today's notice seeks information as to whether persons filing the
RFC> electronic-only preregistration form prescribed by the Copyright
RFC> Office will experience difficulties if it is necessary to use
RFC> Microsoft's Internet Explorer web browser in order to preregister
RFC> a work.

RFC> this notice seeks information whether any potential
RFC> preregistration filers would have difficulties using Internet
RFC> Explorer (version 5.1 or higher) to file preregistration claims,
RFC> and if so, why. More generally, in the interest of achieving
RFC> support for browsers in the Office's preregistration processing
RFC> environment, this notice inquires whether (and why) an eligible
RFC> party who anticipates preregistering a claim on the
RFC> electronic-only form will not be able to use Internet Explorer to
RFC> do so, or will choose not to preregister if it is necessary to
RFC> use Internet Explorer.

[Disclaimer: The DMCA and ART are members of a series of acts that
exceed the constitutional powers of the Congress as stated in Article
I and are incompatible with several of the Amendments known as the
Bill of Rights. The filing of this comment does not constitute tacit

Contents of this comment 1. Browser specific solutions to any problem
should be strictly private 2. Interactive vs. Programmatic approach to
computing 3. Microsoft 4. Some reasons why an eligible party would not
use this. 5. Some questions about the requirements.

1. Browser specific

The Internet was not the first internetwork, and many with expertise
do not consider it to be the technically superior network. Its
superiority consists in providing a non-proprietary system that the
widest variety of computers can use. It is decentralized so that
actors can follow published standards and work independently.

The World Wide Web is a collective public project on the Internet with
certain implicit rules. Contributing a non-standard web page that is
limited to particular browsers violates these rules because the
strength of the Web consists in its accessibility from any browser and
adherence to the World Wide Web standards which guarantee its
universality. This universality enables browsers and programs to be
written that will work anywhere on the Web.

"Anyone who slaps a 'this page is best viewed with Browser X' label
on a Web page appears to be yearning for the bad old days, before
the Web, when you had very little chance of reading a document
written on another computer, another word processor, or another

-Tim Berners-Lee in Technology Review, July 1996

- - - - - -

2. Interactive vs. Programmatic

In a UNIX-like operating environment, the interactive commands for
interactive use overlap almost completely with the commands for
computer programming in that environment. Thus a high degree of
automation is possible.

In the Microsoft DOS/Windows environment, many functions are
exclusively interactive or exclusively programmatic. They are
radically different. Computer programs often require additional
purchases and license restrictions. Thus little automation is
possible. Programming is costly and short-lived because the
environment changes in each OS release.

Form submission to the US Copyright Office is the sort of task in
which automation should be possible, but will likely not be with the
proposed approach to a solution.

- - - - - -

3. Microsoft

Microsoft Corporation has a history of beliefs and practices that make
it unsuitable as a vendor for a government representing the public and
for public use.

The Microsoft program being proposed is source secret and its
requirements include a source secret Microsoft "Operating System" and
connection to the Internet. This gives Microsoft secret access with
full privileges to the computer sending forms to the Copyright Office.
This includes the ability to spy on the machine and alter any file or
log stored on a connected rewriteable device.

Is the preregistration data intended for immediate public release? If
not, what would stop Microsoft from selling data and other
intelligence to others?

Have you considered Microsoft's positions on copyright and related
issues? I would like to call your attention to:

o The patent infringement case of Stac Electronics vs. Microsoft.
Microsoft's settlement was reported to be the largest ever at that

o In the most recent of the series of anti-trust cases, Microsoft's
advocate claimed in the trial that Microsoft owned the copyright to
everyone's screen image if running Microsoft Windows and that a
computer vendor altering a screen layout and the choice of icons for
a customer was infringing on Microsoft's copyright. In the world
according to Microsoft, computer users do not have the right to
arrange their own screen layout or choice of their own programs on
their own machines.

Microsoft is not an acceptable choice for any government work except
for law enforcement and for intelligence gathering that exploits the
vulnerabilities of those careless enough to be using Microsoft

- - - - - -

4. Choice

Any public use of Microsoft spreads their sphere of influence, and
puts pressure against all other systems due to Microsoft
incompatibilities. It also places an unwarranted _imprimatur_ on
Microsoft practices and products.

Any entity bound or inclined to act morally or to work toward goals
such as "public interest" or "progress of arts and sciences" will have
difficulty here because the public use of Microsoft Windows and
related programs vitiates such goals. A policy of not contributing to
illegal acts or criminal activity would also prohibit collaboration
with Microsoft Corporation. It should not be difficult to imagine an
organization formally or informally bound to such a path and thus
unable to use this system.

- - - - - -

5. Questions about requirements

In the "Notice of Proposed Rulemaking" of FR Doc. 05-14516,
preregistration seems to be only allowed via the Preregistration
Application Form (Form PRE). B.1. states: "The Form PRE must be
submitted electronically and will be available only in that form". As
far as I can tell, the contents of the form are entirely simple text.

I was unable to find any clarification of:

a) Why the form cannot be submitted in written or printed medium. A
fixed medium is superior in that it provides a record for the
applicant and is in accord with accepted computer security practice,
as it greatly reduces the chance of tampering. Presumably the point
of this system is to provide a basis for legal recourse, yet
electronic forms on an insecure machine would fall below any
reasonable standard of admissible evidence for documents.

b) Why this is being done through a web-based system when e-mail is
much superior in many ways and is the normal method used.

c) Which properties of the chosen version of the chosen browser
product are considered indispensable? Why would this warrant an
exclusive restriction? If the relevant _desiderata_ were stated,
perhaps alternatives would be forthcoming.

Michael E. Smith
New York, N.Y.


The Copyright Office has asked for comments on whether or not the
proposal to limit submissions to user of Internet Explorer will cause
difficulty. In my view it will. Despite being a user of a
Windows-based PC, I have taken the trouble to install and use two
alternative browsers - Firefox and Opera - simply because of the
appalling security and privacy issues with Internet Explorer.

A government agency should, in my submission, be providing open access
to maximise access to its resources, and as such should follow W3C
standards rather than limit access only to those users who have
subscribed to the commercial offerings of a single company.

Dublin, Ireland


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