UNITED STATES COPYRIGHT OFFICE, LIBRARY OF CONGRESS COMMENT REGARDING SECTION 512 STUDY | DOCKET NO. 2015-7 | COMMENT OF ADAM HOLLAND AND CHRISTOPHER T. BAVITZ ADDRESSING QUESTIONS 11, 15, 25, 29, AND 30 (AND ALL QUESTIONS GENERALLY) | APRIL 1, 2016 | The Cyberlaw Clinic filed this comment on behalf of Adam Holland and Christopher Bavitz, who work on the Berkman Center for Internet & Society’s Lumen project, in connection with the United States Copyright Office’s study concerning Section 512 of the Copyright Act and the safe harbor provisions of the Digital Millennium Copyright Act. The comment highlighted the need for complex policy determinations – like those involving liability and immunity of online platforms – to be based on data and evidence of the sort collected and shared by Lumen. The comment also underscored the value of transparency about takedowns in facilitating clear and manageable processes for all parties in the takedown regime and urged the Copyright Office to encourage further data-sharing to support any efforts to balance the interests of rightsholders, platforms, and users in this space. Harvard Law School students Shoshana Schoenfeld and Jonathan Luebbers, enrolled in the Clinic during the spring term 2016, contributed significantly to the comment.