DCC Written Comments in Response to USTR’s Section 301 Investigation

The Digital Creators Coalition (DCC), representing a broad cross-section of U.S. creative industries, submitted comments to the U.S. Trade Representative in response to the Section 301 investigation of Vietnam's intellectual property acts, policies, and practices. The coalition opposes Vietnam's copyright exception for text and data mining (TDM), enacted in December 2025 and in force since April 2026, which permits AI model training on copyrighted works and sound recordings without authorization or compensation. The DCC argues the exception was adopted without meaningful stakeholder engagement or transparency, and that it is unreasonable and discriminatory because the majority of content available to AI developers in Vietnam is American. Noting that the measure strips U.S. rightsholders of licensing revenue while subsidizing foreign AI developers, the coalition urges the U.S. government to secure Vietnamese commitments to suspend and repeal the exception, respect copyright and voluntary licensing in the U.S.-Vietnam Agreement on Reciprocal Trade, refrain from adopting similar measures, and ensure due process in future copyright rulemaking.