The comments, written by NPPA attorneys Mickey Osterreicher and Alicia Calzada, with contributions from others at NPPA, discuss the myriad of issues currently facing visual journalists regarding their copyrighted images, and offer proposed solutions for creating a system which would treat copyright holders and users of orphaned works fairly and efficiently.
NPPA stated in its comments that it “is gravely concerned that in seeking to address the frustration of ‘good faith users’ of Orphan Works in order to cure their potential liability and ‘gridlock in the digital marketplace,’ the Copyright Office may create a far more serious problem for authors/owners of visual works.”