Publishers told the Copyright Office that licensing is the norm

AAP's own filings date its October and December 2023 comments arguing AI training should follow existing licensing practice.

Historical event

October 30, 2023

First source published

December 6, 2023

Site publication

September 18, 2026

The record

The US Copyright Office opened a public inquiry, Docket No. 2023-6, into artificial intelligence and copyright, and its own policy page states the office 'received over 10,000 comments by the December 2023 deadline.' The Association of American Publishers took part in both rounds. Its own reply comments, filed 6 December 2023, state plainly: 'We filed previous comments on October 30, 2023, during the initial comment round.' In the reply, AAP argues that companies commercializing generative AI 'should be required not only to compensate rights holders for their past ingestion of copyrighted works to train Gen AI systems but also for their ongoing and future use,' and states that 'rights holders today already routinely license their works for all kinds of digital uses,' positioning licensing, not an exemption, as the existing norm the filing asks the office to preserve.

What the documents show

The reply letter itself, an AAP document, dates AAP's initial comments to 30 October 2023, the closing date of the inquiry's first round, and its own filing to 6 December 2023, the reply deadline; a contemporaneous AAP press release confirms the reply's filing and summarizes its argument in the association's own public language. What the inspected documents do not include is the text of AAP's original 30 October filing itself; its content here is known only through the reply's own description of responding to 'flawed and inaccurate assertions' from technology companies in the first round, so the initial letter's precise wording should be treated as undocumented pending direct review of that filing.

Why it stays interesting

AAP's framing rests on an empirical claim, that licensing for digital uses is already routine practice, rather than solely on a legal argument about fair use, which is a notable choice of ground: it asks the office to treat AI training as continuous with an existing licensing market rather than as a novel use requiring new doctrine. This is an editorial reading of the filing's rhetorical strategy, not a claim the Copyright Office itself has adopted, and the office's eventual conclusions are a separate, later record.

What to read next

A reader could check the entry on the EU AI Act's general-purpose model transparency rule for a contrasting regulatory approach built on disclosure rather than licensing, or a record of the Authors Guild's 2023 filing against OpenAI for how an individual creators' organization pursued a parallel claim through litigation rather than agency comment.

• What did AAP's original 30 October 2023 comment letter itself argue, beyond what the reply describes?
• How did the Copyright Office weigh the licensing-market claim against arguments for a fair-use exemption?
• What outcome did the Copyright Office's own study ultimately reach on training-data licensing?

The record supports an initial AAP filing on 30 October 2023 and a reply filing on 6 December 2023, both addressed to the Copyright Office's Docket No. 2023-6, arguing that licensing rather than exemption should govern AI training on published works; it does not, on the documents inspected, include the initial letter's own text or the office's final conclusions, both of which sit outside this record.

Sources & reading trail

AAP's own reply filing, dated 6 December 2023, stating it filed initial comments on 30 October 2023 and arguing for compensation and licensing rather than an AI training exemption.

Source published: 6 December 2023 · Retrieved: 16 September 2026

AAP's own press release summarizing the reply comments' argument for compensating and licensing rights holders.

Source published: 6 December 2023 · Retrieved: 16 September 2026

The Copyright Office's own page describing the Notice of Inquiry docket and stating it received over 10,000 comments by the December 2023 deadline.

Source published: Not established · Retrieved: 16 September 2026

Reports, filings, records and studies establish the entry; the reading of why it stays interesting is Chapter Ledger editorial analysis. This retrospective draft does not imply the site published on the event date.

Continue reading

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• Seventeen novelists sued an AI company as a proposed class
• European publishers asked AI developers for transparency
• Browse the complete the ledger archive

Published September 18, 2026, not on the date of the event described.