Reply Comment on Anticircumvention Rulemaking--Burt

UNITED STATES COPYRIGHT OFFICE Rulemaking on Exemptions from Prohibition on Circumvention of Technological Measures that Control Access to Copyrighted Works Docket No. RM 2002-4 JOINT REPLY COMMENTS ofN2H2, INC.,8e6 Technologies,Bsafe Online,Submitted by:David Burt February 18, 2003N2H2, Inc.900 4th Avenue, Suite 3600Seattle, WA 98164Tel: (206) 982-1130; Fax: (509) 271-4226Email: dburt@n2h2.com1Class of Work and Summaries of the Arguments of Commenters 3About the Joint Commenters 4Introduction 5Summary of Argument in Opposition to the Proposed Exemption 6About Filtering Databases 7The Social Benefits of Filtering Software 9The Evolution of Filtering Industry Markets 11For Economic and Social Reasons, Filtering Companies DoNot Publish Their Databases in the Entirety 13Filtering Companies Provide Free Access to their Databases ThroughQuerying Interfaces and Trial Copies 16Querying is a Well-Established Scientific Method for Evaluating Databases 19Numerous Laboratory Studies of Filter Databases have Used Querying 21Courts have Evaluated Filter Databases Without Research Derived fromCircumventing Copyright Protections 26Government Commissions have Evaluated Filter Databases Without ResearchDerived from Circumventing Copyright Protections 29Journalists have Evaluated Filter Databases Without Research31Commenters Provide No Support for the "Social Benefits" ofCircumventing the Copyright Protections of Filter ...