DCC Written Comments in Response to USTR’s Request for Comments Regarding
the 2025 Special 301 Review

The Digital Creators Coalition (DCC) submitted comments to the U.S. Trade Representative (USTR) regarding the 2025 Special 301 Review, emphasizing the importance of strong copyright protections for the American creative sector in the context of rapidly evolving artificial intelligence (AI) technologies. The DCC, representing diverse stakeholders across creative industries, outlined concerns about AI systems, particularly generative AI (GenAI), being built on unauthorized use of copyrighted materials, and the risks posed by inadequate enforcement and legislative barriers overseas. They highlighted the economic contributions of the U.S. creative sector—accounting for 12.52% of GDP and employing 16.1 million workers—while opposing broad copyright exceptions for text and data mining (TDM), which undermine creators' rights globally. The DCC urged the U.S. to lead international efforts to enforce copyright protections in the AI landscape, promote responsible AI development, and engage with nations implementing or considering TDM exceptions to safeguard the sustainability of the creative economy.