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Final VRA Comments Regarding Proposed CONFU Guidelines
February 25, 1998
Peter N. Fowler
Attorney-Advisor
Office of Legislative and International Affairs
U.S. Patent and Trademark Office
Box 4, Washington, DC 20231
Dear Mr. Fowler:
The Visual Resources Association (VRA), an organization professionally involved with visual materials; their history, production, conservation, and accessibility, has participated in the Conference on Fair Use since the conference was convened by the National Information Infrastructure (NII) Task Force in 1994. It is our belief that to produce guidelines concerning electronic media any time soon would be premature. Further discussion among rights holders, content providers and users of copyrighted materials will be needed before useable guidelines can be crafted.
Above and beyond our belief that adoption of guidelines would be premature, VRA did not endorse any of the CONFU guidelines because of several shortcomings of the documents as proposed. For example, one major concern with the proposed Multimedia Guidelines is the strict limitations on the number of images that may be used for teaching purposes. The Distance Learning Guidelines cover only a very narrow area of use and failed to address digital display at all. Finally, the proposed Guidelines for Digital Images place the burden of clearing the rights to images entirely on the users. The methods described for clearing these rights are completely unworkable since there is nothing yet resembling a "copyright clearance center" for images.
Despite the fact that the process did not yield workable guidelines, we feel that CONFU has been successful in advancing the dialog between content providers and users. Indeed, CONFU has been a vital educational experience for all those concerned with emerging issues of copyright in the digital arena. Please accept these final comments from the VRA as representative of the vast majority of our constituency.
Thank you.
Sincerely,
Joseph Romano, President
Visual Resources Association
Department of Art
Oberlin College
Oberlin, OH 44074
