COMMENT AND REPLY COMMENT OF A COALITION OF MEDICAL DEVICE RESEARCHERS FOR EXEMPTION TO PROHIBITION ON CIRCUMVENTION OF COPYRIGHT PROTECTION SYSTEMS FOR ACCESS CONTROL TECHNOLOGIES | DMCA Anti-Circumvention Exemption Request on behalf of Hugo Campos, Jerome Radcliffe, Karen Sandler, and Benjamin West (No. 2014-07) | February 6, 2015; May 1, 2015 | Following the submission in November 2014 of a petition on behalf of a coalition of medical device researchers, the Cyberlaw Clinic submitted an initial comment and reply comment on behalf of that coalition as part of the Copyright Office and Library of Congress’ sixth triennial rulemaking process.
As set forth in detail in the comments, the coalition proposes an exemption to 17 U.S.C. § 1201(a)(1)(A) for those who access the source code and outputs of medical devices in order to research the safety, security, and effectiveness of such devices. More information about the exemption process is available via the United States Copyright Office website, including copies of all initial comments, opposition comments, and reply comments. For purposes of these proceedings, the Copyright Office designated the coalition’s proposed exemption as “Class 27: Software – Networked Medical Devices.”