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$165 Million Cost Estimate

CO IT Modernization Plan Aims for Shift to Cloud Technologies, Smaller Infrastructure

The Copyright Office said its five-year IT program modernization plan focuses on increasing stakeholders’ use of copyright registration and moving the office away from dependency on a large infrastructure base by using a “variety of cloud strategies.” A “provisional” version of the IT plan released Monday would move the CO’s current paper-based copyright registration to an “automated system where recording parties may enter their own information,” the CO said. Back-end improvements to CO online search functionality will give all stakeholders “dynamic access to the Office’s recordation data,” and the CO will better integrate siloed registration data to provide “a more seamless chain of title from registration to licenses to transfers and the public domain,” the office said. Several copyright stakeholders voiced early praise Monday for the IT plan, saying its high-level priorities stick with the spirit of the CO's 2016-2020 strategic plan (see 1510230042 and 1512010061).

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The CO estimated its IT plan will cost $165 million to implement over five years and will require a $25 million increase in its budget. The CO published its preliminary plan to comply with LOC funding language included in the House Appropriations Committee’s report attached to a short-term continuing resolution that funded the federal government in the days before enactment of the FY 2016 omnibus spending bill. The House Appropriations report required the CO to provide a “detailed plan” for IT upgrades “required for a 21st century copyright organization.” Register of Copyrights Maria Pallante is set to testify for the CO Wednesday as part of House Appropriations’ hearing on FY 2017 appropriations for the Library of Congress. Public comments on the provisional IT plan are due March 31, the CO said in a notice set to appear in Tuesday’s Federal Register.

The CO’s proposal to automate its copyright registration system and other proposed changes will allow the office to “efficiently prioritize its work and leverage synergies across various divisions and statutory duties,” the CO said. It said the changes “will benefit all [CO] systems, including the administration of statutory licenses, public information services, expert impartial assistance to Congress, the courts, and executive branch agencies on questions of copyright law and policy, and its back-office operations.” Proposed changes to the copyright registration system would give users “an array of registration options to choose from, and be able to employ them from mobile devices as well as business-to-business interfaces,” the CO said. “For example, a musician recording a song on a smartphone will be able to seamlessly send her song and the associated data to the Copyright Office for examination and registration.” The CO said it “would exercise quality review consistent” with Copyright Act requirements, including ensuring “priority filing and authoritative information.”

The CO recommended an IT architecture that would “take advantage” of "as a service" IT technologies, proposing to use platform as a service (PaaS)-based mission services that would allow a “limited” transition period and would reduce upfront transition costs. The CO would still own and host a “small, core subset of infrastructure” that would handle user authentication, data backup capabilities and back-office hardware, but would also incorporate cloud-based technologies “where reasonable,” the office said. The CO also considered the use of infrastructure as a service and software as a service technologies but decided a PaaS solution was preferable because it “can deliver mission critical applications and systems in a flexible and scalable manner, with minimal capital expenditures.” The CO said it will ensure its IT modernization plan complies with Federal Risk and Authorization Management Program standards and will “implement greater levels of security of varying degrees depending on the system.”

We’ve been pushing for” a comprehensive IT modernization plan for years, said Copyright Alliance CEO Keith Kupferschmid. He praised the office for basing its provisional plan on a separate CO-specific IT system. The provisional IT modernization plan is “consistent” with both the CO’s 2016-2020 strategic plan and with “steps that stakeholders have been seeking for years,” said Center for the Protection of Intellectual Property Director-Copyright Research and Policy Sandra Aistars. Proposed changes to the copyright registration system will be particularly beneficial since they will “encourage copyright owners to register their works even though they’re not required to do so” to claim copyright protection, Aistars said. Access to “as much information about owners as possible will facilitate business” and “eliminate policy challenges” the CO has faced because of previous gaps in information, she said.

Aistars and Kupferschmid said they hope Pallante’s testimony Wednesday on the CO’s budgetary needs will give stakeholders a better sense of how the office proposes to fund the IT modernization plan. The provisional plan lacks specific funding details. “That’s going to be a significant question,” since CO IT needs have previously been lumped into the general LOC budget, Kupferschmid said. “I’m concerned there will be an attempt” to increase the CO’s reliance on funding from registration fees, which raises the specter of fee increases, he said.