The Copyright Office has been engaged in a multi-year, multi-million dollar project to develop an on-line system for cable operators to use in preparing and filing their semi-annual compulsory license statements of account (SOAs). Previously referred to as the “reengineering project,” the Office has renamed the new system “eLi” (for E-Licensing). It is the Office’s goal to begin a series of voluntary trials of the new system in the second half of the year. At NCTA’s suggestion, the Office is planning to conduct one or more webinars that will allow companies to participate in a demonstration of the new system in advance of deciding whether and when to engage in a trial. The date(s) for the webinar(s) have not yet been determined.

The Office intends to phase-in the trials, starting with a limited number of cable operators of various sizes and, over time, increasing the number of participants so as to better test the real-world capabilities of the new system. At the suggestion of the cable industry, the new system has been designed to allow operators to prepare and submit their filings either individually or in “batches.” One of the challenges that the Office has faced in developing the system has been designing an interface that will allow cable operators to migrate the data needed to complete the form from internal systems. It is expected that the webinar(s) will provide additional information as to how this interface will work.

The forms prepared during the trials will not be used as official submissions. Rather, operators will be expected to use the eLi system to prepare a filing for a previous accounting period to test whether the new system accurately produces the same results as the hard copy system. Recognizing the burden that this “test” filing approach may place on operators and the employees responsible for preparing SOAs, the Office has agreed to be somewhat flexible in terms of the timing of the trials. Thus, while the trials may open as early as this coming July, the Office will not expect responses before October.

Having viewed a demonstration of the new system, it is our recommendation that operators of all sizes consider participating in the upcoming webinar; we also recommend that webinar participants include not only those who currently prepare an operator’s SOAs, but also an IT person who can comment on and raise questions about the technical aspects of the system.

We will continue to monitor the Office’s plans and will report on the dates of the webinar and trials as they are announced. In the meantime, if you are interested in participating in the webinar and/or trials, we urge you to contact us so that we may keep the Office informed of the level of interest within the industry.