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A Comprehensive Guide to Comments Submitted in the Copyright Office’s Notice of Inquiry Regarding U.S. PROs

A guide to comments from PROs, publishers, songwriters and licensees submitted to the U.S. Copyright Office about the way the U.S. PRO system works.

“Coupled with attempts to take advantage of small businesses by relentlessly threatening litigation while failing to provide music users with insight into the repertoires that they represent, such a PRO should certainly be subject to further inquiry.” Read the full comment here. We believe that any existing issues can and should be handled outside of the purview of the U.S. government and can be solved within the industry itself.” The organization also said it “recognizes the concerns from licensees” about the so-called “proliferation” of PROs, but “SONA does not take an official stance in regards to this issue.” Read the comment here. Songwriters Guild of America / Society of Composers and Lyricists / Music Creators of North America: This comment noted that “the independent music creator community agrees without reservation that maintenance of the competitive PRO collective licensing system in the US as described above (including its ‘fractional licensing’ structure) is essential.” In response to licensees’ complaints about there being too many PROs, SGA/MCNA/SCL said these complaints are “a renewed effort by users to invent new, unfounded, inconvenience-based excuses for royalty payment-avoidance supported by no reasonable motivation other than generation of windfall user profits.” Read the comment here.

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