Almost missed this one, but Eric Goldman alerts us to the dozen comments filed with the US Copyright Office concerning its plan to force everyone to keep re-registering their official DMCA agent in order to keep retaining the DMCA's safe harbors. As we've discussed in the past, in order to make use of the DMCA's safe harbors, you have to register an official DMCA agent with the Copyright Office. In fact, we've suggested that anyone running a blog or forum site do exactly that. Many of the companies that were successfully sued by Righthaven (before it was discovered Righthaven didn't really have the copyrights it needed) were caught because they failed to register a DMCA agent. While I think that such sites could make a reasonable argument in court that they still were not liable, it's a lot more difficult (and costly) to do so.
http://www.techdirt.com/articles/20111227/17285417210/copyright-office-seeks-to-make-it-more-difficult-to-retain-dmca-safe-harbors.shtml
http://www.techdirt.com/articles/20111227/17285417210/copyright-office-seeks-to-make-it-more-difficult-to-retain-dmca-safe-harbors.shtml