Here are a couple excerpts from my letter to the Copyright Office:

"[Y]our report gives me the impression that copyright law should exist primarily to facilitate people’s ability to legally make use of existing intellectual properties. In my view, that is a fundamental shift in purpose with potentially terrible consequences. I believe the primary purpose of copyright law is and should be to protect the rights of creators of intellectual property, thereby enabling creators to make a living and create more works."

"I believe your proposed changes to the Copyright Act are trying to solve a problem that is not large or insidious. Indeed, in your own document (pp. 48-49) you state: “We believe, however, that as search capabilities grow and more artists make themselves known via searchable image registries like PLUS (Picture Licensing Universal System), there will be a smaller and smaller likelihood that owners of orphan works will not be able to be connected with those who want to use their works.” I agree with the sentiment that it’s becoming easier to discover the creators of images, although I’m doubtful it’ll be through registries like PLUS.... Since it seems probable that fewer and fewer works will become orphans, why must we drastically change the existing Copyright Act in order to solve a problem that will lessen over time anyway? It seems to me that your proposed “solution” of removing the risks for users of orphan works may cause a much bigger problem than it hopes to solve."