Public Statement of Library Copyright Specialists: Fair Use & Emergency Remote Teaching & Research
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March 13, 2020
This Statement is meant to provide clarity for U.S. colleges and universities about how copyright law applies to the many facets of remote teaching and research in the wake of the COVID-19 outbreak. We write this as copyright specialists at colleges, universities, and other organizations supporting higher education in the U.S. and Canada who work every day with faculty, staff, and librarians to enable them to make ethical and legal choices about copyright issues in online teaching.
The United States is in a time of crisis. As of this writing, more than 200 universities and colleges have moved to remote teaching. These moves aim to promote public health by slowing the spread of the disease, while maintaining at least some of the important functions higher education plays in teaching, learning, and research. We have heard concerns that copyright may pose impediments to a rapid shift to remote instruction, or conversely, that copyright is not relevant. While legal obligations do not automatically dissolve in the face of a public health crisis, U.S. copyright law is, thankfully, well equipped to provide the flexibility necessary for the vast majority of remote learning needed at this time.
Copyright law in the United States is made to support teaching, research, and learning. This stems from its Constitutional purpose, which is “to promote the Progress of Science and the useful Arts.”[1] One critical feature of copyright law is fair use,[2] a flexible users’ right that allows the use of copyrighted works without permission. It accommodates a wide variety of circumstances, including new and rapidly evolving situations. In the words of one of our colleagues, April Hathcock, “fair use is made for just these kinds of contingencies.”
To analyze whether a particular use is fair, courts balance four factors. The “heart of the fair use inquiry” lies in the first factor – the purpose and character of the use.[3] Courts favor uses where the purpose is to benefit the public, even when that benefit is not “direct or tangible.”[4]
Even under normal circumstances, courts favor educational uses because of their broad public benefits.[5] While there are no fair use cases squarely addressing copying to help minimize a public health crisis, the other wide variety of public benefits cited by courts leads us to believe that this purpose would weigh extremely heavily in favor of fair use. For example, in the Authors Guild v. HathiTrust case,[6] the court made it clear that providing access to persons with disabilities was a strong public interest that weighed heavily in the fair use assessment. Similarly, other courts have found that allowing reproduction of the Zapruder film documenting Kennedy's assassination was in the public interest,[7] and allowing redistribution of leaked internal memos about problems with electronic voting machines also favored fair use.[8]
The benefit to the public in providing remote coursework is obvious when it enables teaching to continue in the face of social distancing measures or quarantine, or when access to physical library materials is impossible. The public benefit of these measures is without a doubt of at least equal importance as in these cases.
The second factor examines the nature of the work used—is it more factual or creative, published or not? In cases like this, the second factor “has rarely played a significant role in the determination of a fair use dispute.”[9] For remote teaching in the COVID-19 situation, the analysis should be the same.
The third fair use factor examines the “amount and substantiality” of the work used. Per the Supreme Court, this is a flexible standard that is situation-specific. The third factor is not a mechanical application of a rule such as “no more than 10%” or “1 chapter.”[10] The question is whether “the quantity and value of the materials used ... are reasonable in relation to the purpose of the copying.”[11] For copies made to support rapid adoption of remote teaching, users should be thoughtful about this factor, but not agonize over it: a use can be fair as long as it reproduces what is reasonable to serve the purpose.
The fourth factor is “the effect of the use upon the potential market for or value of the copyrighted work.” This factor “requires a balancing of the benefit the public will derive if the use is permitted” versus “the personal gain the copyright owner will receive if the use is denied.”[12] While in normal circumstances there may be licensing markets for some items, the spontaneity of a move to remote teaching under emergency circumstances reduces the importance of this factor. Checking for and relying on licensed alternatives bolsters the case for fair use under the fourth factor, but lack of time to check for licenses should not be a barrier to meeting the needs of our communities.
Campuses can also consider approaches to mitigate potential risk.[13] Campuses should restrict access to course materials only to students, instructors, or teaching assistants enrolled in the course. Further, they should provide content only for the period of time needed, and excerpt materials when pedagogically appropriate. This limits the possibility of market harm. Ultimately, the purpose of copyright law, “promot[ing] the Progress of Science and useful Arts,” is served by engaging in these time-limited, purpose-specific uses.
It is evident that making materials available and accessible to students in this time of crisis will almost always be a fair use. As long as we are being thoughtful in our analysis and limiting our activities to the specific needs of our patrons during this time of crisis, copyright law supports our uses. The fair use doctrine accommodates the flexibility required by our shared public health crisis, enabling society to function and progress while protecting human life and safety.
We also encourage campuses to begin contemplating the longer-term needs this situation presents. While fair use is absolutely appropriate to support the heightened demands presented by this emergency, if time periods extend further, campuses will need to investigate and adopt solutions tailored for the long-term.
While fair use offers a clear path for most uses in rapidly shifting to remote teaching, some uses raise other concerns. In particular, copying a full-length movie or television episode from a DVD for use in teaching may require circumvention of technical protection measures, which is prohibited under the Digital Millennium Copyright Act (“DMCA”).[14] Like fair use, the DMCA is designed with flexibility in mind—it empowers the Librarian of Congress to create exemptions allowing circumvention under certain circumstances. Unfortunately, the current exemptions[15] extend only to copying “short portions” of motion pictures for use in certain types of teaching, not to copying entire works, even when doing so is clearly fair use. Courts disagree[16] on whether circumvention violates the DMCA when the underlying use is non-infringing (for example, because of fair use) and on what constitutes circumvention. Individual institutions will need to make their own assessments of this issue in consultation with their legal counsel or administration.
When possible, we encourage using video through licensed services. From Netflix, Hulu, and Amazon Prime to PBS and cable channels, many films are readily available, either for free or after payment of a relatively low fee for access.
Some creators and other copyright owners may find this analysis concerning. We offer this analysis from a place of deep respect for creators—and to provide a practical lens through which our colleagues working as instructors and in instructional support positions can keep copyright in mind despite the seismic changes they’re implementing in support of public health.
We encourage the use of already-licensed online content, openly licensed, and public domain alternatives, and working with content vendors to find mutually agreed-on ways to expand existing access to support social distancing for instruction and research. We commend vendors who have stepped up to provide free access to certain resources through the end of the current academic term.[17]
See more Resources on Copyright & Emergency Remote Teaching & Research
(Institutional affiliations listed for identification purposes only)
Emilie Algenio, Copyright/Fair Use Librarian, Texas A&M University Libraries
Sara R. Benson, Copyright Librarian, University of Illinois at Urbana Champaign
Josh Bolick, Scholarly Communication Librarian, University of Kansas Libraries
Justin Lee Bonfiglio, Copyright Specialist, University of Michigan Library
Brandon Butler, Director of Information Policy, University of Virginia Library
Dwayne Buttler, University of Louisville
Will Cross, Director, Copyright & Digital Scholarship Center, North Carolina State University
Kyle K. Courtney, Copyright Advisor, Harvard Library
Kate Dickson, Copyright & Licensing Librarian, University of North Carolina, Charlotte
Amy V. Dygert, Director of Copyright Services, Cornell University
Will Edmiston, Librarian for Copyright & Reserves, The New School
Sandra Aya Enimil, Copyright Services Librarian, The Ohio State University
Ana Enriquez, Scholarly Communications Outreach Librarian, Penn State University
Maryam Fakouri, Copyright Librarian, University of Washington
Sharon E. Farb, Associate University Librarian and Chief Policy Strategist, UCLA
Donna L. Ferullo, Director, University Copyright Office, Purdue University
Katie Fortney, Copyright Policy & Education Officer, California Digital Library
Christine Fruin, Scholarly Communication and Digital Projects Manager, Atla
Agnes Gambill, Head of Scholarly Communications, Appalachian State University
Anne Gilliland, Scholarly Communications Officer, University of North Carolina, Chapel Hill
Liz Hamilton, Copyright Librarian, Northwestern University Libraries and Northwestern University Press
Kiowa Hammons, Rights Clearance Manager, The New York Public Library
Dave Hansen, Associate University Librarian & Lead Copyright and Information Policy Officer, Duke University
April M. Hathcock, Director of Scholarly Communications & Information Policy, New York University
Brandy Karl, Head of the Office of Scholarly Communications and Copyright, Penn State University
Molly Keener, Director of Digital Initiatives & Scholarly Communication, Wake Forest University
Mary Lee Kennedy, Executive Director, Association of Research Libraries
Matthew Kopel, Cornell University
Cindy Kristof, Head, Copyright & Scholarly Communication, Kent State University
Michael Maire Lange, Copyright & Information Policy Specialist, UC Berkeley
Melissa Smith Levine, Director, Copyright Office, University of Michigan Library
Yuan Li, Scholarly Communications Librarian, Princeton University Library
Lisa A. Macklin, Associate Dean for Research, Engagement, and Scholarly Communications, Emory University Libraries
Peter Midgley, Director, Copyright Licensing Office, Brigham Young University
Carla Myers, Coordinator of Scholarly Communications, Miami University
Darcee Olson, Copyright and Scholarly Communications Policy Director, Louisiana State University
Nazareth A. Pantaloni, III, Head, Copyright Program, Indiana University Libraries
Rina Elster Pantalony, Director, Copyright Advisory Services, Columbia University Libraries
Laura Quilter, Copyright and Information Policy, University of Massachusetts Amherst
Charlotte Roh, Scholarly Communications Librarian, University of San Francisco
Rachael Samberg, Scholarly Communication Officer & Program Director, UC Berkeley
LeEtta Schmidt, Copyright and Intellectual Property Librarian, University of South Florida
Nancy Sims, Copyright Program Librarian, University of Minnesota Libraries
Kevin L Smith, Dean of Libraries, University of Kansas
Stephen Spong, Law Library Director, Western University
Stephanie Towery, Copyright Officer, Texas State University
Nate Wise, Intellectual Property Office Manager, Brigham Young University - Idaho
Stephen M. Wolfson, Research and Copyright Services Librarian, University of Georgia
Timothy Vollmer, Scholarly Communication & Copyright Librarian, UC Berkeley
Micah Zeller, Head of Scholarly Communication Services, Washington University in St. Louis
Katie Zimmerman, Director of Copyright Strategy, MIT Libraries
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(Institutional affiliations listed for identification purposes only)
Andrew Kierig, Interim OER, Scholarly Communications, and Copyright Lead, George Mason University Libraries
Sarah McCleskey, Head of Resource & Collection Services, Hofstra
Anne E. McKee, Program Officer for Resource Sharing, Greater Western Library Alliance
Megan Gaffney, Coordinator, Interlibrary Loan and Document Delivery Services, University of Delaware
Harrison W. Inefuku, Scholarly Publishing Services Librarian, Iowa State University
Karen Estlund, Dean of Libraries, Colorado State University
Heather Joseph , Executive Director, SPARC
Karen Hines, Professor of Business, Berkshire Community College
Martin Kalfatovic, Associate Director, Smithsonian Libraries
Alexia Hudson-Ward , Azariah Smith Root Director of Libraries , Oberlin College and Conservatory
Nahali R. Croft, Digital Archivist, Georgia College
Perry Collins, Scholarly Communications Librarian, University of Florida
Kathleen DeLaurenti, Head Librarian, The Peabody Institute of Johns Hopkins University
Dennis Clark, Dean, University Libraries, University of Arkansas
Rachel Schnepper, Director of Academic Technology, Wesleyan University, CT, USA
Barbara Dewey, Dean of University Libraries and Scholarly Communications, The Pennsylvania State University
Howard Besser, Professor, New York University
Pia M. Hunter, Teaching Assistant Professor, University of Illinois College of Law
Samuel Trosow, Associate Professor, University of Western Ontario
Aaron W Dobbs, Scholarly Communication Librarian, Shippensburg University of Pennsylvania
Beth Williams, Senior Director, Robert Crown Law Library & Senior Lecturer in Law, Stanford Law School
Anne Langley , Dean, UConn Library, University of Connecticut
Amanda Runyon, Associate Dean and Director, Biddle Law Library, University of Pennsylvania Carey Law School
Chris Bourg, Director of Libraries, MIT
Corey Seeman, Director, Kresge Library Services (Ross School of Business), University of Michigan
Lorelei Sterling, Head of Access Services, interim, University of Alaska Anchorage
Danielle M. Williams , Director of First-Year Writing, Baylor University
Sophie Forrester, User Experience and Technology Librarian, Lasell University
Amanda Watson, Director of the O’Quinn Law Library, Assistant Professor, University of Houston Law Center
Megan Donald, Interim Director, Mabee Legal Information Center, University of Tulsa College of Law
Abigail Phillips, Assistant Professor, University of Wisconsin-Milwaukee
Billie Jo Kaufman, Interim Law Library Director & Visiting Professor of Law, Mercer University Law School
Matthew Vest, Music Librarian , UCLA
Linda Dempf, Music and Media Librarian, The College of New Jersey
Hilary Seo, Interim Dean of Library Services, Iowa State University
Megan A. Brooks, Dean of Library Services, Wheaton College MA
Alexia Hudson-Ward , Azariah Smith Root Director of Libraries , Oberlin College and Conservatory
Michelle Oswell, Library Director, Curtis Institute of Music
Violeta Ilik, Head, Digital Collections and Preservation Systems, Columbia University
Joseph A. Salem, Jr., Dean of Libraries, Michigan State University
Maura Smale, Chief Librarian and Professor, NYC College of Technology, CUNY
R Sekhar Chivukula, Professor of Physics, UC San Diego
Kathryn Loomis, Teaching Fellow, University of North Texas
Christine Heron, Senior Librarian, Genesee District Library
Celia Rabinowitz, Dean of Mason Library, Keene State College
Carolyn S. Brodie, Professor Emeriti , Kent State University, School of Information
Heather Slania, Director, MICA’s Decker Library, Maryland Institute College of Art
R. David Lankes, Professor and Director, School of Library and Information Science, University of South Carolina
Katie McNamara, Teacher Librarian, CSLA President, North High & Fresno Pacific University
Brad Warren, Associate Dean of Library Services, University of Cincinnati
Peace Ossom-Williamson, Director of Research Data Services, The University of Texas at Arlington
Courtney Selby, Associate Dean for Library Services and Associate Professor of Legal Research, St. John’s University School of Law
Jonah McAllister-Erickson, Scholarly Communication Specialist , University of Pittsburgh
Katie Willeford, Learning Resources Librarian, University of Texas at Arlington
Jill Hurst-Wahl, Professor of Practice, Syracuse University
Shannon DeSantis Gile, School Librarian, Lamoille South Unified Union School District
Jen Waller, Director of Open Initiatives and Scholarly Communication, University of Oklahoma
Bryan M. Carson, Library Director (and copyright attorney), Missouri Valley College
Miriam Deutch, Associate Professor, Brooklyn College, City University of New York
Ada Emmett, librarian and director, Shulenburger Office of Scholarly Communication & Copyright, University of Kansas
Dorothy Meaney, Director, Tisch Library, Tufts University
David Scherer, Scholarly Communications and Research Curation Consultant, Carnegie Mellon University
Sue Ann Gardner, Scholarly Communications Librarian, University of Nebraska-Lincoln
Paul Royster, Coordinator of Scholarly Communication , University of Nebraska-Lincoln
Donna Reed, Ph.D., Dean of Library and Learning Resources, City College of San Francisco
Anne M. Young, Director of Legal Affairs and Intellectual Property, Newfields
Colleen Lyon, Head of Scholarly Communications, UT Austin
Inga H. Barnello, Director of the Library, Le Moyne College
Kristen M. Burkholder, Access Services Librarian & Associate Professor, Oklahoma City University
Stephanie Davis-Kahl, Collections & Scholarly Communication Librarian, Illinois Wesleyan University
Robin N Sinn, Coordinator, Office of Scholarly Communication, Sheridan Libraries, Johns Hopkins University
Fruma Mohrer, (former) Chief Archivist, I endorse use of copyrighted items for long distance classroom learning during virus crisis, Yivo Institute for Jewish Research (former)
Christin , Wixson, Scholarly Communication Librarian, Plymouth State University
Nicoladie Tam, Associate Professor, University of North Texas
Amanda Page, Digital Curation Librarian, Hamilton College
Karen Bleier, Collection Mgmt & Resource Sharing Librarian, Park University
Amy Hoseth, Assistant Dean, Colorado State University Libraries
Sue Kunda, Scholarly Communications and Social Science Librarian, Western Oregon University
Steven D. Hinckley, Associate Dean for Library and Information Services, Penn State Law/Penn State University
Heather Soyka, Assistant Professor, Kent State University iSchool
Jennie Rose Halperin, Assistant Director for Outreach and Community Engagement, Harvard Law School Library
Megan Wacha, Scholarly Communications Librarian, City University of New York
Nora Allred, Assistant Director for Scholarly Communications, Michigan Technological University
Elizabeth Berney, Content & Delivery Services Librarian, Northern Arizona University
Marcia Keyser, Online Graduate Support Librarian, Drake University
Ryan Otto, Scholarly Communication Librarian, Kansas State University
Lauren Ginsberg DeVilbiss, Librarian , NYC Dept of Education
Deborah L. Heller, Acting Director of the Law Library, Elisabeth Haub School of Law at Pace University
Steve Oberg, Group Leader for Research Description and Digital Initiatives, Wheaton College (IL)
Rachel Bridgewater, Reference, Instruction, and Copyright Librarian, Portland Community College
Hao Zeng, Head of Library Web and Digital Services, Yeshiva University
Leila Belle Sterman, Scholarly Communication Librarian, Montana State University
Georgia Westbrook, OER & Instruction Librarian, Touro College
Alex R. Hodges, Director, Gutman Library, Harvard Graduate School of Education
Jennifer L. Pate, Scholarly Communications and Instructional Services Librarian, University of North Alabama
Maurine McCourry, Library Director, Hillsdale College
Lindsey Weeramuni, Intellectual Property Manager, MIT Office of Digital Learning
Paul Scott Lapinski, Associate Director, Scholarly Communication & Open Science, Harvard Medical School
John O'Connor, Scholarly Communications Librarian, Boston College
Martin J. Brennan, Scholarly Communication Education Librarian, UCLA Library
Susan LaGatta, School Library Media Specialist, Mary E. Roberts Elementary School
Julia Simic, Assistant Head of Digital Scholarship Services, Digital Production and Preservation, University of Oregon
Elsa Loftis, Humanities and Acquisitions Librarian , Portland State University
Ann Buehl, District Library Media Director, Parkview School District
Kristen Hoffman, Psychology and Scholarly Communications Librarian, Seattle Pacific University
Larry Harkcom, Distance Education Librarian, Southwestern College
Millie Gonzalez, Digital Services Librarian, Framingham State University
Rick Davis, Copyright & Scholarly Communications Librarian, Towson University
University Library Faculty Council, California State University Long Beach
Jay Starratt, Dean of Libraries, Washington State University
Anne Marie Doyle, School librarian, Dunn’s corners elementary school
Hillary Miller, Scholarly Communications Librarian, Virginia Commonwealth University
Andrew Ashton, Director of the Libraries, Vassar College
John Edward Martin, Scholarly Communication Librarian, University of North Texas
Gregory Lum, Library Director, Clark Library of Jesuit High School, Portland, OR
Lisa Macklem, PhD Candidate, University of Western Ontario
Nicholas Netzel, Librarian, Central Catholic High School, Portland, OR
Carrie A. L. Nelson, Director of Scholarly Communication, University of Wisconsin-Madison
Jessica Lorentz Smith, Teacher Librarian , Bend Senior High School
Frederick D. Barnhart, Dean of University Libraries, Northern Illinois University
Jennifer Beamer , Scholarly Communication Librarian (Coordinator), The Claremont Colleges Library
James M. Darlack, Director of Goddard Library, Gordon-Conwell Theological Seminary
Allegra Swift, Scholarly Communications Librarian, UC San Diego
Michelle Speed, Librarian, North Central Texas College, Corinth Campus Library
Jennifer Chan, Scholarly Communication Librarian, UCLA
Joshua Zeller, Access Services Coordinator, Mount St. Joseph University
Julie Patricia, Associate Librarian, Ada Community Library
Chris Freeland, Director of Open Libraries, Internet Archive
Melissa H. Cantrell, Scholarly Communication Librarian, University of Colorado Boulder
Andrea Wirth, Scholarly Communication Librarian, University of Nevada, Las Vegas
Kristine Alpi, University Librarian, Oregon Health & Sciences University
Michaela Willi Hooper, OER & Textbook Affordability Librarian, Linn-Benton Community College
Mark G. Bilby, Scholarly Communications Librarian, California State University, Fullerton
Anne Shelley, Scholarly Communication Librarian, Illinois State University
Andrew Bonamici, University Librarian, Drew University, Madison, New Jersey
Daniel Chamberlain, Associate Librarian for Digital Strategies, Dartmouth Library
Anita Coleman, Director of Library Services and Professor of Bibliography and Research, Louisville Presbyterian Theological Seminary
Lindsey Gumb, Scholarly Communications Librarian, Roger Williams University
Patrick Carr, Program Manager for Library Consortium Operations, Connecticut State Colleges & Universities
Tracey E Mendoza, Dean of Libraries, University of the Incarnate Word
Clarke Iakovakis, Scholarly Services Librarian, Oklahoma State University
Tim Pyatt, Dean, Wake Forest University
David Banush, Dean of Libraries and Academic Information Resources, Tulane University
Larissa Gordon, Scholarly Communications Librarian, Thomas Jefferson University
Tammy Ravas, Arts and Media Librarian and Copyright Coordinator, University of Montana
Simon Neame, Dean, University Libraries, UMass Amherst
Sreedevi Satyavolu, Head of Access Services, Catholic University of America
Emily Johnson, Scholarly Communication Librarian, The University of Texas at San Antonio
Posie Aagaard, Assistant Dean for Collections & Curriculum Support, The University of Texas at San Antonio
John Burger, Executve Director, Association of Southeastern Research Libraries (ASERL)
Anne Cooper Moore, Dean, J. Murrey Atkins Library, UNC Charlotte
Rayne Vieger, OER & eLearning Librarian, University of Oregon
Claire Stewart, Dean of Libraries, University of Nebraska-Lincoln
Christopher Cox, Dean of Libraries, Clemson University
Renee D Carey, Librarian, Faith Bible College, Virginia
Nancy A. Gutierrez, Dean, College of Liberal Arts & Sciences, University of North Carolina, Charlotte
Ken Burhanna, Dean of University Libraries, Kent State University
Emily G. Finch, Scholarly Communications and Copyright Librarian, Kansas State University
Deborah Lilton, Reference & Embedded Librarian, Tennessee State University
Abigail Noland, Systems Librarian, University of Mount Union
Alison Cole, Computing & Information Technology Librarian, Felician University
Felice Maciejewski, University Librarian, Dominican University
Jacob Jeremiah, Assistant Dean of Library, Oakton Community College
Grover Baker, Visual and Performing Arts Librarian, Middle Tennessee State University
Mary Heinzman, Executive Director of Information Resources, St. Ambrose University
Michelle Gohr, First Year Experience Librarian, Arizona State University
Victoria A. Hart, Director of Library Resources, Northeast Lakeview College
Annette Cunningham, EC Teacher, Charlotte Mecklenburg School
Denise Woetzel, Reference/Information Literacy Librarian, Reynolds Community College
Patricia Aufderheide, University Professor, School of Communication, American University
Leslie Potter-Henderson, Acting Associate Dean, Shoreline Community College
Hayley Marie Flanagan
Serenity Ibsen, Director of Library Services, Pacific Northwest College of Art
Jeanmarc Raynal
Sarah Williams, Faculty, The Evergreen State College
Polly Thistlethwaite, Interim University Dean for Library Services, City University of New York
Katherine Furlong, Executive Director, Research Services & Digital Scholarship, Bucknell University
Dr Jean T Kreamer, Copyright Oversight Officer, Retired, University of Louisiana
Kari Rigg, Teacher Librarian, Lincoln Options Elementary
Ellen Dubinsky, Scholarly Communication Librarian, University of Arizona
Michael Diltz, Librarian, Sabin Elementary School Portland, OR.
Danette R. Pachtner, Librarian for Film, Video & Digital Media and Women's Studies, Duke University
Howard Besser, Professor, New York University
Calvin Wang, Assistant Professor, Science Librarian, Copyright Consultant, Arcadia University
Andrew Weiss, Digital Services Librarian, California State University, Northridge
Sara Parme, Scholarly Communications/Digital Initiatives Librarian, Indiana University of Pennsylvania
Peter Suber, Director, Office for Scholarly Communication , Harvard University
Sheila Snow-Croft, Director, Network of Alabama Academic Libraries, Alabama Commission on Higher Education
Dalia L. Corkrum, Library Director, Whitman College
Steve Vercusky, Spiritual Molecular Institute
Dan Bowell, University Librarian / Director of the Library, Taylor University
Jason Griffey, Director of Strategic Initiatives, National Information Standards Organization
Ellen Euler, Prof. Dr., University of Applied Science Potsdam
Christine Beachler, Library Media Director, Lowell Area Schools
Adam Burke, Librarian, Waubonsee Community College
Bebe S. Chang, Archives & Digital Librarian, Nova Southeastern University
AJ Boston, Scholarly Communication Librarian, Murray State University
Heather W Novotny, Librarian, The McGillis School
Stacy Chapman, library assistant, The Oakridge School
Carmen Mitchell, Scholarly Communication Librarian, California State University San Marcos
Troy Christenson, Resource Delivery Librarian, The University of Texas at Arlington
Helen Tang, Librarian, University of Toronto
Raymond Pun, Instruction/Research Librarian, Alder Graduate School of Education
Lucy Gan, Information Services Librarian, Cheng Yu Tung East Asian Library, University of Toronto
Kael Moffat, Information Literacy Librarian, Saint Martin's University
Jennryn Wetzler, Assistant Director of Open Education, Creative Commons
DEBORA VISCARDI, CUSTOM BROKER, ISF srl
Alicia Hansen, Head of Research, Teaching & Learning, College of the Holy Cross (MA)
Davida Scharf, Director of Reference & Instruction, New Jersey Institute of Technology
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[4] Sega Enterprises Ltd. v. Accolade, Inc., 977 F.2d 1510, 1523 (9th Cir. 1992), as amended (Jan. 6, 1993)
[10] Cambridge Univ. Press v. Becker, 863 F. Supp. 2d 1190 (N.D. Ga. 2012), rev'd sub nom. Cambridge Univ. Press v. Patton, 769 F.3d 1232 (11th Cir. 2014)