Remember when we asked you to comment on the Copyright Office rulemaking for compulsory (or “statutory”) mechanical licenses? We’ll be posting some of the comments that did go up on the Copyright Office site starting with this one from Chris Castle at MusicTechPolicy

Music Technology Policy

We’re all mad here…

Alice’s Adventures in Wonderland, by Lewis Carroll

The following are my initial comments to the current proposed rulemaking at the Copyright Office that would, in my view, give digital streaming services a pass on transparency and accountability for their extraordinarily low royalty payments.  The reporting on the ridiculously low royalty payments from services like Spotify assume one key fact that is not in evidence–that the royalty, however low, is calculated correctly.

Given the extraordinary sloppiness in the compulsory licensing system and the prohibition in the Copyright Act against songwriters and artists being able to audit statutory mechanical royalty payments, I have to agree with National Music Publishers Association President and CEO David Israelite (quoted again below): “It’s almost as if you had a tax system where there were no penalties if you didn’t file your taxes.”  First they take away the songwriter’s right to…

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