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Before the

Washington, D.C.

In the Matter of:
Docket No. 2015-7
U.S. Copyright Office Section 512 Study

Sony Music Entertainment (“Sony”) is pleased to provide these Comments in response to
the Copyright Office’s (the “Office”) Notice of Inquiry (“NOI”) concerning its Section 512
Study. 1

Sony’s business is focused on producing, manufacturing, distributing, selling, licensing,
and otherwise exploiting audio and audiovisual recordings (“Sony Recordings”) throughout the
world. Its well-known and respected music labels – which include Columbia, RCA, Epic, Sony
Nashville, Legacy, and Sony Masterworks, among others – are home to some of the most
popular and successful recording artists of all-time, including Michael Jackson, Bob Dylan,
Bruce Springsteen, Beyoncé, Pharrell Williams, Adele, and Miles Davis, to name just a few.
Sony’s catalog consists of more than one million discreet sound recordings. Sony risks hundreds
of millions of dollars each year recording, marketing, and distributing the creative works of its
new and existing artists.

The issues raised by the NOI are critically important to Sony’s business and its artists, as
Sony Recordings were the subject of over 5.7 million takedown notices (“Takedown Notices”)
sent in 2015 pursuant to 17 U.S.C. § 512 (“Section 512”) or pursuant to substantially similar

Section 512 Study: Notice and Request for Public Comment, 80 Fed. Reg. 81,862 (Dec. 31, 2015).

instructions required by various digital services. Despite the significant time, energy, and
resources expended by Sony to locate and deliver such a massive number of Takedown Notices
to strategically targeted sites, infringing copies of Sony Recordings persist on these sites and
elsewhere on the Internet.

Because a diverse coalition of various music industry companies and entities (including
Sony) is also submitting a comprehensive joint response to the NOI on behalf of the music
community at large (“Music Community Comments”), in these comments we only address a
subset of the inquiries set forth in the Office’s NOI.

4. How have Section 512’s limitations on liability for online service providers
impacted the protection and value of copyrighted works, including licensing
markets for such works?
Section 512 has had a significant, negative effect on the value of copyrighted works and
the ability of copyright owners to license those works for online uses.

One principal benefit of owning a copyright is the exclusive right to control the
exploitation of the covered work, as that general right is codified and described in Section 106 of
the Copyright Act. The economic value of a copyrighted work is directly dependant on that right.
While the staggering expansion of the Internet has in many ways spurred incredible growth and
success for Sony’s digital business, the vast scale of this new Internet ecosystem, when
combined with the unchecked and unintended expansion of Section 512’s safe harbor, has led to
a severe drag on even greater growth for Sony’s business in this otherwise exciting time. The
judicially expanded safe harbor provisions in Section 512 have combined with the Internet’s
massive scale to virtually strip copyright owners like Sony of their ability to prevent the
unauthorized exploitation of their works, thereby undermining the market for licensing those

works. The economic value of musical works now depends significantly on the amount of money
and resources the copyright owner is prepared to, and capable of, spending to fight infringement
in an attempt to regain some control over that work.

For example, Sony is essentially forced to pay a third party contractor to search for and
claim or block otherwise infringing videos on YouTube that are not caught by YouTube’s
Content ID system. 2 Since December 2012 this contractor has identified and claimed or blocked
1,488,035 infringing copies of Sony Recordings not identified by Content ID. The failure of
Content ID to identify the videos that Sony identified and claimed through its contractor’s work
would have cost Sony and its artists $7.7 million dollars in revenue from approximately 10
billion plays were it not for Sony’s contractor’s independent efforts. Furthermore, these numbers
are merely the silver lining to a much larger problem created by a music service of YouTube’s
scale relying on Section 512, as untold millions in revenue will never be realized by Sony due to
plays of Sony Recordings that Content ID does not identify and Sony’s contractor has yet to, if
ever, identify. For reasons discussed in greater detail in Sony’s response to the Office’s inquiry
#4 herein, the unauthorized availability of these Sony Recordings on YouTube results in a loss of
significant revenue as those infringing copies displace legitimate sales and streams of the Sony
Recordings on similar music download and/or streaming services that do not rely on Section 512
and pay fair market rates. 3


See generally How Content ID works,

See, e.g., International Federation of the Phonographic Industry’s submission to the Public consultation on the
regulatory environment for platforms, online intermediaries, data and cloud computing and the collaborative
economy (“[O]ur member companies, as content producers, are unable to negotiate fair commercial contractual
terms with some online platforms, specifically those that rely on user-uploaded content such as YouTube,
Dailymotion and Soundcloud.).


Meanwhile, the very same combination of the Internet’s scale and Section 512 safe
harbors has been a boon to popular websites and services that rely on user uploads as the source
of the content they use to attract audience, and more often than not, significant advertising and
other revenue (“Uploaded Content Services”). 4 Section 512 effectively grants to Uploaded
Content Services a constructive royalty-free license, under which companies can confidently
profit from the massive copyright infringement occurring on their platforms without any fear of
liability. The process of relying on users to acquire popular copyrighted content without
authorization is so reliable that seeking a license from Sony for the exploitation of Sony
Recordings is unnecessary for Uploaded Content Services. By providing their users with easy-touse upload functionality these services invite their users to provide Sony Recordings for free.
These unlicensed services compete directly with Sony’s licensed partners, eroding the value of
those partners’ businesses and the revenue that licensed services can return to Sony and its

Given the foregoing, it is unsurprising that Sony routinely finds that new digital platforms
do not commence negotiations with Sony for a license covering the Sony Recordings they are
already exploiting until Sony devotes substantial resources to remove infringing copies of Sony
Recordings from those platforms via Takedown Notices. Even then, in Sony’s experience, these
Services often refuse to pay market rates for the use of Sony Recordings. Rather, their
willingness to negotiate a royalty rate is calculated solely on the basis of the incremental value
that a direct license and relationship with rights holders can provide above the effective royalty-


Nothing contained in this filing with the Office shall operate as an admission or acknowledgement by Sony that
any of the services or activities discussed herein are entitled to rely on the safe harbor provisions of Section 512.
Sony endorses the Music Community Comments’ response to the Office’s inquiry #2, describing how courts have
improperly construed the entities and activities covered by the Section 512 safe harbor.


free license enabled by Section 512, plus marginal cost savings that can be achieved from not
having to continuously comply with the Takedown Notices from Sony.

For example, in May of 2015, after discovering a substantial amount of infringing Sony
Recordings on the popular Uploaded Content Service Dubsmash, 5 Sony attempted to engage in
discussions with the German owner of the service (Mobile Motion GmbH) regarding the
authorization of the use of Sony Recordings on Dubsmash. By November, after several
unsuccessful attempts to commence serious discussions, Sony was left with the familiar burden
of having to remove unauthorized Sony Recordings from Dubsmash through Takedown Notices.
Just three weeks after Sony began sending Takedown Notices, Mobile Motion stopped
complying with the Takedown Notices. Mobile Motion shortly thereafter requested that Sony
stop sending Takedown Notices and indicated that they would like to discuss an agreement to
exploit Sony Recordings on the platform. Despite this request for renewed discussions, massive
amounts of infringing copies of Sony Recordings remain on the platform, and to date Sony has
been unable to make meaningful progress towards an agreement that is in line with market rates
for comparable services or some other resolution with Mobile Motion.

The commercial impact of Section 512 is not limited to unlicensed services. Section 512
has the effect of materially diminishing Sony’s leverage in direct licensing discussions with
Uploaded Content Services. By way of example, the licenses entered into by many ad-supported
Uploaded Content Services provide for substantially lower rates to Sony than the rates paid by
similar music streaming services that do not rely on Section 512. In determining whether to
license such ad-supported services at lower rates than Sony’s standard rates, Sony is faced with

See Note Dubsmash has filed a DMCA designated agent with the U.S. copyright
office though its terms of service claim it is under German law. See and


an excruciating dilemma. While Sony aims to support the value of music in the market by
insisting on fair payments that will sustain its artists and the still nascent streaming business, a
license for Sony’s entire repertoire to an on-demand, ad-supported music service relying on
Section 512 at sub-par rates is inconsistent with that objective. But if Sony stands firm, insisting
on rates in line with fair market value, and an Uploaded Content Service walks away from the
deal, Sony is then left with nothing except the Sisyphean task of trying to keep its content off of
that service indefinitely.

5. Do the section 512 safe harbors strike the correct balance between copyright
owners and online service providers?
Whatever balance that existed at the inception of Section 512 has been undone by overly
broad interpretations of the scope of Section 512 safe harbors and the unanticipated and ever
expanding scale of the Internet.

As a result of broad interpretations of the classes of Uploaded Content Services that may
be entitled to Section 512 safe harbor protections, the number and variety of such services
continues to grow at an astounding rate. This expansion of what constitutes a “service provider”
results in the safe harbors no longer just applying to passive and/or neutral intermediaries as
originally intended.

Today, Sony must expend significant resources in an attempt to police the vast Internet in
search of infringing copies of Sony Recordings. On the other hand, entertainment platforms
holding themselves out as passive Uploaded Content Services, which in the aggregate garner
huge user bases and generate billions of dollars in ad revenue largely attributable to the
infringing activity on their platforms, have no obligation to monitor their platforms for


infringement beyond complying with Takedown Notices and implementing a policy to ban
repeat infringers. This state of affairs demonstrates a clear imbalance between the burdens placed
on copyright owners and service providers in the present reality of Section 512.

For example, prior to reaching a licensing agreement with the popular music focused
Uploaded Content Service SoundCloud, from April 1, 2015 to April 1, 2016 Sony spent
hundreds of thousands of dollars to manually review 1.5 million metadata matches and to send
Takedown Notices to remove approximately 218,000 infringing copies of Sony Recordings from
the Sound Cloud platform. Despite the scale of this enormous effort, it was only sufficient to
monitor approximately 15% of Sony’s catalog on this single platform. Prior to the takedowns,
these infringing copies of Sony Recordings amassed over two billion unremunerated plays,
representing millions of dollars in lost revenue as they displaced sales and plays of these Sony
Recordings on licensed, revenue generating platforms.

While Section 512 forces Sony to expend significant resources, it places no obligation on
sites and services that profit from such infringement at Sony’s expense, to provide any tools to
assist Sony in finding infringing copies of Sony Recordings on such sites and services. Despite
the fact that in a few cases Uploaded Content Services provided tools to assist Sony in
identifying and removing infringing copies of Sony Recordings, the vast majority of Uploaded
Content Services do nothing beyond the bare minimum requirements of Section 512 to provide
the contact information for the relevant service’s copyright agent. In some cases services actually
rig the game to frustrate Sony and other copyright owners’ efforts to remove infringing materials
from their platform, increasing the burden Section 512 places on copyright owners in addressing
online infringement.


Even aspects of an Uploaded Content Service’s design can frustrate efforts to identify
and remove infringing material. The general “Search” function on Uploaded Content Services
routinely returns hundreds and in some cases even thousands of search results which bear little
relation to the search query used. The result is that Sony is left in the dark as to the scope of
potentially infringing works available on the service. As an example, without sophisticated
processes and tools developed by recording industry trade bodies, 6 Sony would have been left to
manually review over 32 million search results using SoundCloud’s native “Search” function to
search for infringing copies of Sony Recordings. Instead, using these processes and tools, Sony
was able to cut the number of search results down to a still imposing, but at least more accurate,
1.5 million results to review.

In the case of another popular video focused Uploaded Content Service, using the search
query “Uptown Funk” returned 21,200 results relevant to the query while only providing access
to the first 60 videos responsive to the query. This functionality makes it virtually impossible for
Sony to review potentially infringing videos on the service beyond the initial 60 videos.

6. How effective is section 512's notice-and-takedown process for addressing online
As we have addressed elsewhere in these comments, Section 512 is deficient as a
deterrent and solution to online infringement and will only become more so as the number and
variety of Uploaded Content Services continue to proliferate.

The Music Community Comments provide an in depth response to the Office’s inquiry
#6 fully setting forth comprehensive data demonstrating that Section 512 has done very little to
effectively address online infringement. Sony agrees with the Music Community’s fuller

The Recording Industry Association of America and the IFPI.


response, and would like to provide a supplemental response raising an issue relevant to Sony’s
experience that is of increasing concern and which further demonstrates that Section 512’s
notice-and-takedown process is an ineffective and un-adaptable remedy for an ever changing and
innovating online environment.

With respect to live streams and other types of dynamic audio and audiovisual content
streamed by services such as Twitch, TuneIn, Periscope, Facebook Live, and YouTube Connect,
to name a few (“Live Streaming Services”), Section 512 is a blunt and ineffective tool. In these
cases, a particular URL generally will point to a stream of content that is exclusively or at least
significantly infringing, but it will point to an infringement of a particular copyright owner’s
work only intermittently (e.g. when its recording or music video is played), and it may at times
point to non-infringing content (e.g. video showing a user reaction to a stream of an infringing
music video).

For infringements such as these that are fleeting in nature, Section 512 provides an
ineffective remedy. The infringement and all the consumption related to it have already occurred
before Sony can marshal its efforts to send a takedown. By way of example, Sony has sent
Takedown Notices to the webcasting service TuneIn relating to hundreds of stations on which
Sony observed infringing streams of Sony Recordings. There are apparently over 100,000
stations available on the TuneIn platform, and available information concerning use of the
Section 114 statutory license suggests that no more than a small fraction of those stations are
licensed in the United States. However, monitoring stations for plays of Sony Recordings is
incredibly resource-intensive because of the real-time nature of the streams. And it is anomalous
that when infringements are found, Sony must send the Takedown Notices with respect to


infringements that happened in the past, while the service has moved on to infringe other works.
While TuneIn has removed many stations on which Sony has observed infringement, it is trivial
for infringing webcasters to resume their infringements on a new TuneIn station, and TuneIn has
resisted removal of all stations of infringing webcasters, even though each has almost certainly
infringed the copyrights in hundreds or even thousands of recordings by the time Sony observes
an infringement of a Sony Recording by the webcaster.

10. Does the notice-and-takedown process sufficiently address the reappearance of
infringing material previously removed by a service provider in response to a
notice? If not, what should be done to address this concern?
As interpreted by the courts and implemented by most services, Section 512’s notice-andtakedown process does nothing to address the reappearance of infringing material. This is a huge
problem for popular works that are constantly uploaded and hence continuously available even
when copyright owners focus their limited resources to remove them.

One of the largest contributing factors to the high cost of content protection for rights
holders is the need to continually notify a site or service that a particular recording is not
authorized on that platform each time a new copy of that same recording is uploaded. In the case
of a popular new sound recording like Beyoncé’s “Formation,” Sony faces an unceasing burden
to monitor innumerable popular platforms with millions, and in some cases billions of users,
constantly uploading content. Furthermore, while Sony may find and send takedown notices for
hundreds of copies of Formation from a particular site, even just a single unauthorized copy that
remains available (or reappears) on the site for users to stream or download renders Sony’s
takedown efforts entirely futile.


Put another way, the rate at which additional infringing copies of Sony’s most popular
(and most valuable) recordings are uploaded by users for streaming or downloading by others on
the most popular sites will virtually always be greater than the rate at which Sony can take the
infringing copies down without devoting a commercially unsustainable amount of resources to
each individual recording. When Sony recording artist Future released his album entitled “DS2”
in 2015, a particular SoundCloud user uploaded all of the tracks from the album to the service.
When Sony removed the tracks via Takedown Notice, the tracks were re-uploaded by the same
user minutes later. This cycle was repeated multiple times before the user finally appeared to
relent. 7 This one example reflects only a small part of the effort it takes to keep a popular album
like DS2 off of unauthorized sites. It also illustrates that the task of keeping a Sony Recording off
unauthorized platforms is especially difficult around the initial release date of the recording,
when its availability on unauthorized platforms is especially damaging commercially for the
artist and Sony.

To provide another example of the difficulty Sony faces in its efforts to prevent popular
recordings from reappearing after the initial Takedown Notice, despite the fact that SoundCloud
employs various voluntary measures to reduce infringement, including filtering, for Mark
Ronson’s “Uptown Funk”, Sony and its trade bodies manually removed 3,211 additional
infringing copies on SoundCloud that were missed by SoundCloud’s filter following delivery of
the initial Takedown Notice. Despite this effort, as of March 29, 2016, there were 11 infringing
copies of Uptown Funk available for the millions of SoundCloud users to stream. For the
157,181 discreet Sony Recordings that Sony has monitored on SoundCloud to date, Sony must

It is worth noting that under SoundCloud’s repeat infringer policy, this user would only receive one “strike”
against their account because SoundCloud (in addition other sites such as YouTube, Facebook, and Twitter) counts
all Takedown Notices received in a 24 hour period as one “strike”. So this user would not be removed from the
service as a “repeat infringer” under Section 512.


manually review approximately 1,100 new uploads associated with those Sony Recordings per

Given the massive scale of the Internet and the ever expanding number of individual
platforms, it is not a reasonable solution to leave it to a content owner; much less a content
owner of a substantial volume of works such as Sony, to continually police the entirety of the
Internet to prevent violations of its rights. At a bare minimum, if a copyright owner has identified
a particular work as not being authorized for exploitation on a particular service, that service
should have a duty of care to take those measures that are necessary to ensure that the service
does not thereafter infringe that same work. This “takedown staydown” compromise should be
effectuated either by adoption of “standard technical measures” pursuant to Section 512(i) or by
Congressional action.

15. Please describe, and assess the effectiveness or ineffectiveness of, voluntary
measures and best practices—including financial measures, content “filtering” and
takedown procedures—that have been undertaken by interested parties to
supplement or improve the efficacy of Section 512’s notice-and-takedown process.
In a limited number of cases, voluntary measures taken by third party platforms to curtail
infringement have marginally assisted Sony in managing infringing copies of Sony Recordings
on those platforms. However, such measures are not sufficient.

While Sony and the larger music community have had some success in partnering with
intermediaries on responsible practices to reduce the level of infringements occurring online, in
many instances, voluntary measures by Uploaded Content Services are poorly implemented,
which can entirely undermine their effectiveness. For reasons discussed above in response to the
Office’s inquiry #10, if even a single copy of a particular work slips by a filter, in practical terms


it is tantamount to a failure by the filter to lessen the availability of that work on the service at
all. Simply having a “fingerprinting solution” in place to block infringing uploads is meaningless
without effective implementation of such solutions.

With no visibility afforded copyright owners and no accountability under the law,
services have a perverse incentive to identify as little infringing content as possible. The better
job a service does of implementing effective filtering solutions or providing robust content
removal tools to content owners, the greater the amount of valuable but infringing content on
their platform will be removed or filtered and/or more friction with the service’s user base will
be created. Furthermore, services are actually disincentivized from implementing more robust
solutions and policies to reduce infringement, because such actions arguably provide services
with either “actual” or “red flag” knowledge of who the actual copyright owners are and that
infringement is occurring, which could disqualify the services from the safe harbor. Conversely,
services that do nothing to curb infringement on their platform are not only rewarded with an
ever-expanding catalog of infringing content to exploit, they immunize themselves from any
claim that they have acquired actual knowledge of infringement occurring on their platform.

The effects of this perverse incentive are evidenced by the fact that while technological
filtering solutions available to Uploaded Content Services have improved dramatically in recent
years, Sony nonetheless typically spends over one million dollars a year to remove or claim just
a small fraction of Sony’s catalog of Sony Recordings solely from YouTube, a platform widely
regarded as employing robust voluntary measures to prevent copyright infringement.

In the summer and fall of 2015, several multiplatinum artists requested that Sony keep
their respective new single and/or album off of YouTube and/or SoundCloud. In each case, Sony

committed to each of the artists representatives that it would coordinate efforts to maintain the
“takedown” on the site(s) concerned for a period of a few weeks as designated by the artist. For
the YouTube Platform, Sony turned to a contractor that Sony regularly retains to police the
YouTube platform. But to ensure these singles and albums were completely removed from
YouTube, Sony needed to hire two additional contractors that provide similar services. Although
three separate contractors vigilantly blocked the relevant recordings over the focus period,
consumer views of each user uploaded file they identified and took down over the entire period
of weeks for each recording generally exceeded several thousand views (in some cases hundreds
of thousands and even millions of views) before the files were identified and taken down. The
current whack-a-mole system allows meaningful unremunerated consumption of content by
consumers even when all possible steps are taken to prevent it.

With regard to SoundCloud, Sony dedicated 16 full time resources to monitor the
SoundCloud platform to locate unauthorized user uploads containing Sony Recordings. Sony
identified 1.5 million files that contained metadata corresponding to the tracks being searched.
Given the nature of the content available on the platform, Sony then reviewed each file manually
to determine the contents of the file and the context in which Sony Recordings were used. While
Sony’s efforts resulted in 218,000 takedowns, the effort covered barely more than 15% of Sony’s
catalog. The cost and effort expended by Sony for this size of a project would not be sustainable
if applied across Sony’s entire catalog of recordings.

In some cases, online platforms simply choose not to filter certain types of content as it
suits their platform and strategy. For example, a service may take the position that anything less
than a 100% match by the fingerprinting solution will not be blocked or removed from the


platform. This position allows the voluntary “filter” to ignore a five minute song if only four
minutes and thirty seconds of the song appears on the platform. This is particularly problematic
as more and more popular Uploaded Content Services will happily make do with smaller and
smaller portions of Sony Recordings, needing only the “heart” of these recordings to derive
significant value from them.

These services are empowered to make this arbitrary determination because there is no
transparency or accountability. As long as the algorithm employed to identify infringing content
is set to match only 100% matches, the fingerprinting solution will not identify infringing
content that is less than a 100% match in the fingerprinting solutions algorithm, and therefore the
service employing the fingerprinting solution will not disable access or remove the infringing

26. Is section 512(g)(2)(C), which requires a copyright owner to bring a federal
lawsuit within ten business days to keep allegedly infringing content offline—and a
counter-notifying party to defend any such lawsuit—a reasonable and effective
provision? If not, how might it be improved?
One of the necessary assumptions of services that rely on end users to provide them with
significant amounts of infringing content for their platforms is that copyright owners cannot and
will not undertake the impractical task of suing the services’ millions of users. Putting aside the
potential public relations impact, suing individual users for one-off infringements, many of
whom may have no substantial assets or may be located overseas, in overburdened courts in
which cases can linger for years, would be the height of inefficiency and would have little to no
effect on the reduction in levels of infringing content. Furthermore, had Congress anticipated the
current scale of the notice and takedown economy, it would not have enacted a solution that


resulted in copyright owners catastrophically clogging up federal court dockets with hundreds of
thousands, if not millions, of infringement cases, as a viable remedy for addressing infringement.

Leaving aside the foregoing wider policy implications, no rational company could or
would routinely bring lawsuits solely to remove individual pieces of content from a website in a
world where Google alone is on pace to receive over 1 billion takedown notices 8 this year. In
fact, despite the millions upon millions of Takedown Notices sent by or on behalf of Sony since
Section 512 went into effect, Sony has not once found it to be commercially reasonable to sue an
individual infringer pursuant to 512(g)(2)(C). To further illustrate the impracticality of this
remedy, since 2008, thousands of videos infringing Sony’s copyrights have been reinstated on
YouTube due to counter notifications not being contested by Sony pursuant to 512(g)(2)(C). In
the vast majority of those instances, there was no legitimate question that the use infringed
Sony’s exclusive rights. However, given that Sony already typically expends a million dollars a
year policing the YouTube platform, it would not be reasonable for Sony to spend significant
additional outlays on litigation in order to ensure just a tiny fraction of the hundreds of thousands
of videos claimed or removed from the platform, stay off the platform.

This problem is exacerbated by the ease by which users may file a counter notification.
Many Uploaded Content Services provide counter notification forms to their users, and users
submit those forms without having to provide any legal or factual basis for the counter
notification beyond a perfunctory statement that he/she believes that the material was removed
“as a result of mistake or misidentification” – nothing more. These forms typically allow users to


TorrentFreak, Google Asked to Remove 100,000 ‘Pirate Links’ Every Hour (March 6, 2016), (estimating that Google
will have to process a billion reported links this year alone, a milestone which previously took over a decade to


contest a Takedown Notice, regardless of the merits, in a matter of minutes by providing their name
and contact information and clicking a few checkboxes. These erroneous counter notifications add
yet another layer to complex task of taking down infringing copies of Sony Recordings and keeping
them down.

Since the distant threat of litigation against end users is not an effective deterrent against
erroneous counter notifications or a viable remedy in practice, some “duty of care” or other
accountability should be placed on service providers operating under the safe harbors of Section
512 to implement a process to deal with clearly erroneous counter notifications. At present, such
services are able to turn a blind eye to clearly erroneous counter notifications, which allows them
to continue to exploit tremendous volumes of infringing content.

Sony greatly appreciates the Office’s consideration of these comments and the
opportunity to participate in the Office’s study of Section 512. For all of the reasons described
herein as well as in the in the Music Community Comments, Sony strongly urges the Office to
advise Congress to reform Section 512.


April 1, 2016

Respectfully Submitted,

'1ulie Swidler
Executive Vice President, Business Affairs & General
Counsel (Global)
L. Jeff Walker
Executive Vice President, Business & Legal Affairs,
Global Digital Business
David Jacoby
Senior Vice President, Business & Legal Affairs
Don I. Jang
Vice President, Anti-Piracy, Global Digital Business
Marques S. Johnson
Senior Director, Business & Legal Affairs, Global
Digital Business
25 Madison Ave., New York, NY 10010