Comments regarding the periodic review of Mechanical Licensing Collective designations

Comments Submitted by the Songwriters Guild of America, Inc., the Society of Composers & Lyricists, Music Creators North America

Re: Periodic Review of the Designations of the Mechanical Licensing Collective and Digital Licensee Coordinator (Docket No. 2024-1)

The Songwriters Guild of America (“SGA”), the Society of Composers & Lyricists (“SCL”), and Music Creators North America (“MCNA”) are a coalition of independent music creator advocacy organizations (together, “Independent Music Creators”) whose interests in protecting and advancing the rights of the tens of thousands of independent American songwriters, composers and lyricists are neither influenced nor compromised by conflicts of interest. Our collective mission, initially launched by SGA nearly a century ago, can be accurately summarized in three simple words” “Protect Music Creators.”

The Independent Music Creators thank the Librarian of Congress (“LOC”) and the US Copyright Office (“USCO”) for the opportunity to submit these Comments concerning the periodic five-year review for re-designation of the current Mechanical Licensing Collective (“MLC”) and the Digital Licensee Coordinator (“DLC”) as viewed solely from the perspective of creators and authors– the group whom Congress is primarily authorized and encouraged to protect under the Article I Section 8 of the US Constitution.

The purpose of these Comments is to formally indicate a willingness on the part of the Independent Music Creator community to support current MLC and DLC re-designation, but only if certain changes in policy as enumerated herein giving greater consideration to music creator interests and generating more robust MLC transparency and fairness can be agreed upon and implemented.

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