FTC DRM comments

Comments 102-202
downloaded from http://www.ftc.gov/os/comments/drmtechnologies/
Comment Number: 539814-00102
Received: 1/8/2009 9:05:42 PM
Organization:
Commenter: Jack Colby
State: NY
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

If a company feels the need to have an install limit, it should be mandated (or otherwise strongly recommended) that an activation revoke tool be in place AND that the install limit not be used in versions of the software that utilize Steam or another digital distribution service with its own DRM.
Comment Number: 539814-00103
Received: 1/8/2009 9:05:57 PM
Organization:
Commenter: Stephen Gibson
State: Outside the United States
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I feel that DRM does little to help the game/software industry. At best, it's a minor inconvenience for pirates. They will always find a way to beat it, meanwhile honest consumers are being punished and limited with products they have purchased. Better pricing, and more friendly policies are the way to stop people pirating (see: GoodOldGames.com, who have no DRM and excellent pricing), not enforcing strict limitations on how and where something can be used.
Comment Number: 539814-00104
Received: 1/8/2009 9:10:19 PM
Organization:
Commenter: Ashkan Foroughi
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Dear FTC, I would like to make my stance on this issue clear. I am not an advocate of DRM. If DRM actually accomplished anything for publishers then I might see the use in plaguing a consumer's system with malware in an attempt to frivolously stop piracy. However, allow me to show how DRM does not work. Spore, a game by EA, is notorious for having the most well-known DRM ever released by a publisher. How did the DRM fair? Spore became the most pirated game ever within months of its release. The saddest part is that the people who pirated the game didn't have to worry about DRM or limited installs, while legitimate consumers have to suffer with the processor-slowing SecuROM DRM and are given only a limited number of installs. This fiasco is enough to show that the almost nonexistent so-called "advantages" to DRM are GREATLY outweighed by the disadvantages. DRM only helps to create a sense of mistrust between the consumer and publisher by forcing actual consumers to be punished for potential piracy which they are not partaking in. As such, it is my utmost wish that the FTC please disable the use of invasive and dangerous DRM. Sincerely, Ashkan Foroughi
Comment Number: 539814-00105
Received: 1/8/2009 9:10:39 PM
Organization:
Commenter: Mark Williams
State: NV
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

To state it bluntly, DRM is bad and does not work. The very nature of it as "technologies typically used by hardware manufacturers, publishers, and copyright holders to attempt to control how consumers access and use media and entertainment contentquot; is wrong. It makes media bought by consumers into something they don't really own. People who buy books are not forced to use them in a certain way, and neither should people who buy electronic media. Regarding its purpose to stem file sharing, it does not work. When the public is determined enough to break laws, in the multitudes, and when the future points to free and open media, there is nothing that can or should be done to stop it.
Comment Number: 539814-00106
Received: 1/8/2009 9:12:31 PM
Organization:
Commenter: Jeffrey Kelly
State: NY
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Digital Rights Management technologies are a major problem in the digital entertainment industry. Content publishers are constantly turning to ever more intrusive methods of copy protection, which invariably have little to no effect on piracy. The people who wish to illegally copy and distribute content are many, and they are dedicated and skillful. It is almost inconceivable to think of a copy protection method that would be truly successful in stopping them. The copy protection methods currently employed by many providers often have a negative effect on honest users, while being easily removable by illegitimate owners. In no other industry is this more true than the video game industry. More and more computer games are being shipped with limiting, unfair, sometimes even harmful copy protection software. For example, a copy protection method called StarForce was recently employed by several game publishers. Game pirates were able to easily "crack" the protection within just a few days. People who had legally purchased the games on the other hand were forced to deal with long StarForce "checks" at the beginning of each game, common false positives where StarForce would refuse to open the game even when no illegal activity was occuring and, in some cases, StarForce even caused permanent, irreversible damage to DVD drives. A more recent example of this is the DRM software employed by Electronic Arts on their game "Spore". The DRM limited the user to only 3 installations of the game, before they would be required to contact Electronic Arts support to "renew" their licenses. This also created the problem of whether or not the game would be usable a long time from now. Electronic Arts' support services will of course not exist forever. The DRM that was in place on the game would prevent users from playing the game that they had legally purchased, should Electronic Arts' support ever fail or be closed. On an ironic note, "Spore" was listed as the single most pirated game of 2008. This is a perfect illustration of the idea that DRM systems only serve to hinder the legitimate user, while pirates are able to easily bypass them and, in many cases, obtain a more functional product. When those who steal a product get a better, more functional experience than those who pay for it, there is clearly something wrong. Thank you for your time, Jeff K.
Comment Number: 539814-00107
Received: 1/8/2009 9:12:46 PM
Organization:
Commenter: Adamski
State: CT
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is the ruination of replayability, I don't pay for a game just to install it 3 times when illegal downloads don't have that limit. All it does is make pirating a better looking option.
Comment Number: 539814-00108
Received: 1/8/2009 9:13:25 PM
Organization:
Commenter: Michael Torres
State: NY
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

The older anti-piracy measures were far better. A simple disk check will suffice. I didn't even mind checking page 93 for the third word in the second paragraph back in the day. I have a copy of Dreamfall sitting on my shelf unopened. It has been sitting there unopened for over a year because I keep meaning to try and find out if it has that dreaded Starfrorce DRM. Why should I, a paying customer, have to be fearful of installing a game on my system while pirates get to enjoy the same game without paying and without suffering the misery of parasitic DRM schemes. I buy games from Steam all the time. Their approach to DRM is perfectly fine with me. All these other measures where games install virus-like software have got to go.
Comment Number: 539814-00109
Received: 1/8/2009 9:15:07 PM
Organization:
Commenter: Matt Scanlon
State: WI
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I am writing to express my staunch opposition to the use of DRM in both computer software and music. It serves to restrict fair use by an end user who paid money to use said product. At the same time it disproportionately punishes law abiding citizens. The spectre of software and music piracy exists despite DRM. Thus, citizens who do not practice piracy are limited in legitimate use while the DRM has effectively done nothing to prevent illegal use. I support software and music publishers the rights to enforce their copyright protection. That said, to do so with fundamentally flawed technology that only punishes people who pay for the product are injust, punitive and should not be allowed.
Comment Number: 539814-00110
Received: 1/8/2009 9:15:22 PM
Organization:
Commenter: Justin York
State: ME
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Thank you for the use of this form. I just wanted to write to the FTC to say that as a paying gamer, DRM is a nuisance at best and never ever ever stops the serious pirates. It's a fact. Please don't punish the paying customers.
Comment Number: 539814-00111
Received: 1/8/2009 9:16:53 PM
Organization:
Commenter: Ashton Knudsen
State: RI
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is not a good way for companies to regulate their assets. While there is a valid point with them trying to stop piracy, there is truly no stopping a determined hacker. That DRM measure will be taken down within days of the software being released. DRM has devolved into a simple way for companies to stop consumers from sharing any of their products, forcing others to buy the product themselves if they want to experience it on their own at all. This is unfair to the consumer. Is there any other product in the world that can be controlled in such a way? Food can be shared, hardware can be shared, pretty much anything else can be shared. Why should software be so special?
Comment Number: 539814-00112
Received: 1/8/2009 9:16:54 PM
Organization:
Commenter: M Dodds
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I feel that DRM hurts LEGITIMATE buyers more than anything. Pirate WILL crack it. Pirates will crack it the VERY FIRST DAY IT'S OUT! Or they will get a leaked version and crack it BEFORE THE PRODUCT IS EVEN ON RETAIL SHELVES. There is nothing I hate more than DRM. I'm mainly talking videogames here. I avoided Spore all together with the DRM headaches. Secu ROM is the devil. I find this to be a good example. Look how rampant piracy was with that videogame. Look at the DRM in place on that game. Most gamers did not want to deal with that bullshit. No matter how much you limit a product. No matter how much "protection" you place on that product, it's going to get cracked within a matter of hours. Which in the end only hurts legitimate consumers of that product. The pirates will just be on their merry little way playing the DRM free version of the game.
Comment Number: 539814-00113
Received: 1/8/2009 9:20:20 PM
Organization:
Commenter: Jeremy Corff
State: TX
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

To whom it may concern, The only persons effected demonstrably effected by DRM are paying customers. Buy purchasing products with DRM on them customers are subjecting themselves to inconvenience and hassle, while those who choose not to pay and simply pirate the product have no such problems. You could make a strong argument that this actually leads more people to pirate products with DRM than would otherwise be the case. Of course theft is a problem, but DRM is not the solution. Thank you.
Comment Number: 539814-00114
Received: 1/8/2009 9:20:20 PM
Organization:
Commenter: Robert Sigler
State: NJ
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I believe that DRM is needed for the industry's protection, however, it needs to be monitored. The monitoring is necessary because there are forms of DRM that lock out certain consumer bases (see EA's most recent PC games, Spore and Command & Conquer: Red Alert 3 for examples), often times by NEEDING an internet connection (see: Starforce and Steam) or some other mildly invasive/restrictive means. Also, I believe DRM in digital music is prohibitive. It is too varied in limitation, and, as in Apple's case, stops the consumer from using the program/product of their choice to listen to their music. I believe sales would increase if digitally bought music were able to be used on any given product (MP3 player, PC, etc.). It is my belief that DRM, in general, needs to be evaluated, as well as better advertised, to aid the consumer in their purchases and choices.
Comment Number: 539814-00115
Received: 1/8/2009 9:23:35 PM
Organization:
Commenter: Meder
State: WI
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM takes many forms. Making my objections to them many and varied. SecuRom (and related software) is additional, unadvertised, and mandatory, software that is installed concurrently with program purchased by the consumer. Oftentimes it interferes with the performance of the computer it's installed on, can not be removed, and may even open so-called back doors making it accessible to hackers and harder to defend against viruses. Additionally, there are authenticators and product keys. These are less invasive, but directly violate the First-Sale Doctrine of 1909, and later the Copyright Act of 1976 (17 U.S.C. Section 109) by preventing or interfering with the transfer of a copy of a product once it has been obtained. Product keys are often good only for one activation, rendering the product useless to anyone but the original purchaser. This is a direct, willful, and unlawful violation of consumer rights. Losing the product key (which, invariably, will not be replaced by the manufacturer) may even result in a consumer being banned from using a product they have lawfully acquired, which violates 17 U.S.C. Section 106 and 106A. Setting install limits, as sensationalized in Electronic Art's 2008 Spore, to limit the fair use of a product appears to also be in conflict with 17 U.S.C. Sections 106 and 106A. Overall, DRM to date has been a clear and unlawful violation of consumer rights, and one that the American people should not stand for.
Comment Number: 539814-00116
Received: 1/8/2009 9:23:49 PM
Organization:
Commenter: Peter Singley
State: NJ
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

As someone familiar with the means and methods of people engaging in activities DRM hopes to hinder, I can say one thing with certainty. DRM does nothing to deter these illicit users, and does everything to hinder legitimate use by those who don't circumvent DRM.
Comment Number: 539814-00117
Received: 1/8/2009 9:25:26 PM
Organization:
Commenter: Steven Rowe
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I think DRM is not needed. :\
Comment Number: 539814-00118
Received: 1/8/2009 9:26:34 PM
Organization:
Commenter: Cooper
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM does nothing to stop pirates. To the average user, they are frustrating, invasive and unnecessary. DRM counts against the ownership of a product, and infringes upon the rights of the user.
Comment Number: 539814-00119
Received: 1/8/2009 9:28:42 PM
Organization: Sony Computer Entertainment of America
Commenter: Scott Soltero
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I am against all forms of DRM. I believe that pirates will be pirates no matter what form of security is used on any form of media. The only thing I see DRM doing is causing more people to go out an pirate media so they can avoid the inconvenience of DRM. Personally, I am a consumer first and do not partake in pirating media because I work in the games industry. I feel very strongly about artists being paid for use of their creations.
Comment Number: 539814-00120
Received: 1/8/2009 9:29:05 PM
Organization:
Commenter: Anthony Markesino
State: TX
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is very important to protect the initial sale and recompense of the developer and publisher. However, DRM must accomplish this without violating the privacy of the owner (purchaser of said product) and they should be able to use it in any way they see fit as long as it is for their own personal use and not to directly make a profit. DRM must not invade the individuals privacy, it should not force them to patch to play (the product should be complete and runnable without access to the internet unless specifically stated, a major failure with games for windows products which require you to login to windows live). Licensing when you purchase a video game should only include that skew (platform you purchased it for), however the owner (purchaser) should reserve the right to modify and use said product on any platform he can without reprocussion (emulator's and rom's). It should be noted that even games with similar names built for different skews are different, so purchasing a copy of Commandoes for Wii is an inherently different product then Commandoes for PC. However, if you can through the use of an emulator enable your copy of Commandoes for Wii to run on your PC or other device (including a portable device), this should be considered legitimate. Developers and Publishers should make no effort to prevent this use. DRM to be effective without hindering owners and the marketplace needs to be nearly invisible and non-invasive. Some of the best forms of DRM are physical. ex1. Bard's Tale and the Zork series required the owner to periodically check the owners manual. (Ciphers with a physical key are also good) ex2. writing to a particular Hard Drive during installation then generating a key with a one time online registration are good, but alternate registration via phone should be available as well as support for using this product on more then one machine if the original is damaged (Bioshock did this to fairly good effect, taking the mac-address of each machine to generate a single use key). I personally advocate as part of a hardware solution is making a writeable portion of a disk that can be flashed to prevent use on other machines in effect providing the key as well as the cipher on a single disk. (The best example would be the smart cards at several universities, most of the date is stored in traditional magnetic tape and online while critical data, in this case the key to allow play and decide authorized machines is contained in the smart chip). Video Games DRM should allow resale, otherwise the product loses all value upon initial sale and damages any chance of recompense from pirates because once it has been bought once, it in effect isn't valued as a new game but only as a perishable one use one owner item. While this isn't very economical for the developer/publisher, it maintains the rights of the consumer over property they purchase. The consumer should always have the right to transfer ownership of said property. Please withhold any identifying and personal information except my first and last name from the public record.
Comment Number: 539814-00121
Received: 1/8/2009 9:29:40 PM
Organization:
Commenter: Rich Whitman
State: IL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I feel that DRM, if it is allowed at all, should at a minimum, be fully disclosed to the consumer on product packaging. I also feel in the long run, DRM will harm the industries that use it, as the customer learns legitimate copies of media are actually inferior to their pirated equivalents. This is not just a monetary issue. For example, many Compact Discs use DRM which prevent their music from being transferred to an MP3 player, which is well within a consumer's fair use. I hope that the FTC will see fit to severely limit, or entirely eliminate, the use of DRM. I believe any use of DRM will eventually become overly invasive and anti-consumer.
Comment Number: 539814-00122
Received: 1/8/2009 9:29:52 PM
Organization:
Commenter: Josh Jertberg
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

The HDMI HDCP handshake is a huge problem. How can consumers embrace new advances such as 1080P pictures and 7.1 sound if the device compatability is patchy. I technically have all the equipment needed to enjoy 7.1 sound from my PS3, but the HDMI HDCP handshake prevents me from using this function. Contacting hardware companys only leads to finger pointing, each one proclaiming thier device is not the problem. I would love to see 1080p picture and 7.1 sound become embraced technologies, but when you spend thousands of dollars specifically for this type of output only to find a HDCP bug well that makes me want to boycott HDMI until its resolved. The idea that it exists to protect content, and legitimate setups cannot play them to full capacity is very wrong. Thank you
Comment Number: 539814-00123
Received: 1/8/2009 9:33:40 PM
Organization: Private
Commenter: Joshua Tolentino
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Manufacturer's and publisher's comments that DRM is entirely necessary to prevent piracy are in large part erroneous or even misleading. --- There are no studies that have definitively shown that the presence or absence of DRM measures have increased or decreased overall sales of any game respectively. And as can be shown by various statistics-tracking firms, the presence of DRM is rarely if ever a deterrent for prospective pirates, said pirates often able to -crack- a game's DRM measures even before release day. --- A large portion of users are actually troubled by DRM because of the system instability and compatibility problems brought upon by DRM measures. Given the way they operate, hiding themselves from the system and disabling or hindering completely normal system operations that on occasion permit the use of copied software, DRM measures would be considered "malware" if viewed in any other context. ---- DRM further harms the rights of the consumer to the product he or she owns. DRM prevents the resale of a product, limits the amount of times a product can be installed on a given computer, and serves only to allow publishers more and more control over their customers, control that is neither warranted nor wanted.---- The justification that a consumer is only buying a "license" to a given product and not the product itself is spurious and misleading, as it is based on a contract that can only be signed by the consumer "after-the-fact", in that the consumer has already bought the product before he or she knows what she is buying. This would be illegal if applied to most other products. Would you agree to buy a car if the seller refused to tell you details about the warranty, engine performance, or ride comfort, only saying that you'd know once you bought it? ---- As a result, DRM is a security measure that does not prevent the supposed crime it is supposed to protect from, regardless of the actual damage said crime does (see above the lack of definitive proof that software piracy damages sales), and only harms the legitimate consumer in the process. ----- I strongly urge the commission to take a stand for consumer rights and encourage the prevention of piracy via better business practices, better products, and cultivating consumer loyalty, rather than through expensive and ultimately ineffective means that damage both goodwill and consumer rights. ----- Thank you for your time and consideration.
Comment Number: 539814-00124
Received: 1/8/2009 9:34:13 PM
Organization: Decolumnized Gaming
Commenter: Alex Watson
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

There are various sources stating that DRM doesn't work. When someone purchases a game, they want to be able to play the game, without worrying that, should they want to install it someplace else, or, for that matter, should they reformat their computer, and reinstall it, they won't be able to play their game. It's perfectly acceptable for game developers to want to protect their interests, but not at the expense of accessability for people who have bought the game. DRM is not the answer.
Comment Number: 539814-00125
Received: 1/8/2009 9:37:25 PM
Organization:
Commenter: Siegel
State: MD
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is an unnecessary pain that is currently driving people away from the online entertainment industry in general. It is affecting the economy in a negative way because it conjures bad perceptions of products with DRM.
Comment Number: 539814-00126
Received: 1/8/2009 9:40:58 PM
Organization:
Commenter: Jason Reagan
State: KY
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I will make this short and simple. DRM doesn't work. Pirates still pirate and the only people that are punished is the people that legitimately buy the product. I have had two computer systems crashed due to overprotective DRM management. It has become easier for me to pirate software instead of buying it and jumping through hoops to use it.
Comment Number: 539814-00127
Received: 1/8/2009 9:41:28 PM
Organization:
Commenter: Sean Stran
State: MD
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Dear FTC, The progression of DRM has and always will lag behind the progression of piracy. Those who wish to circumvent the law have no rules, and use any means possible. Companies have used many methods as DRM, and they have always failed. The sheer fact that the content exists in any form on whatever medium allows for the professional to extract it, regardless of the encryption. Where methods of DRM do not work for companies, associations like the RIAA are formed. These groups wish to bully the "ignorant" who are normal consumers teased by the "hardcore" pirates of the industry with promises of "free" and "pain-free" media. Something that those pirates do in fact deliver and profit from, something that consumers want. Where all of this comes to concern is the consumer. With each new method of DRM, comes new restrictions. X song can only be used on Y device for Z many times. Not to the pirate, just to the "law abiding" consumer. Not only have the various industries put more and more restrictions into their media, they have gone as far as profiting from their newly made DRM-ridden products. Not the pirate though, he will continue to get the media, for free, as he wishes. The consumer once again suffers, having to pay 2, 3, 4 times for essentially the same media, because he wants to listen to it at home and also on the road. The question arises then; how to cull the piracy and also allow companies to properly protect their intellectual property? Unfortunately this commenter does not have the answer, but it is in my opinion that the current methods used serve only to hurt the paying consumer, and do nothing to stop piracy. Thank you for your consideration in this matter
Comment Number: 539814-00128
Received: 1/8/2009 9:42:38 PM
Organization: Meta-Games Unlimited
Commenter: Jeff Winters
State: MO
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

My personal belief, and the belief conveyed to me by many of our customers is that the current way DRM is applied to PC software does not allow the buyer to own the game in the traditional sense of ownership. The way DRM has been applied in the past year or so makes buying computer software feel a lot more like renting a game than owning it, which inevitabley is deterring sales and having negative impacts on PC gaming. I would feel much better if companies would follow the Steam and Blizzard models as apposed to making games uninstallable after only a few installs.
Comment Number: 539814-00129
Received: 1/8/2009 9:44:38 PM
Organization:
Commenter: Nicholas Salyers
State: AL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is a solution to a problem created in and of itself by DRM. It holds good honest users hostage to seemingly invincible measures of discomfort while being a simple time waster for even the least experienced pirate. Computer programmers and musicians alike have proven that preventing piracy is as easy as making it worth consumer's while by both including special features and items and providing updates via the internet, and this has proven that consumers are willing to pay for programs and music, if it turns out that the product is indeed worth the price. Were programmers to lower their price, I guarantee they would see an increase in sales. Simple, free market economics. Thank you for your time.
Comment Number: 539814-00130
Received: 1/8/2009 9:44:50 PM
Organization:
Commenter: David Lessard
State: VA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I am against DRM in all forms. It only hurts and limits those that rightly pay for digital property. If someone illegally gets the media, they will circumvent it and have no restrictions on it, but if someone pays for the media, there will be all of the restrictions. It is illegal to circumvent, but a fact of life that hackers will get around DRM somehow - the Internet is just too robust at this point. This just punishes the people who actually monetarily support the media producers. People should be punished for following the law. If people go through all the trouble to circumvent DRM or file share, they weren't going to buy the product anyways, so DRM does not prevent piracy. It is unfair to the common consumer. If I purchase a product, there should not be restrictions on how I use it.
Comment Number: 539814-00131
Received: 1/8/2009 9:52:34 PM
Organization:
Commenter: Albinson
State: MN
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I believe DRM restricts our rights of ownership. If one buys a product--music, a video game, a film, they are given the right to use that product as many times as they want (unless specified otherwise as in a subscription). DRM restricts this right by limiting their right to reuse their owned product. It should be within the owner's power to use that product for themselves on whatever device wherever they are. A restriction of this right is unreasonable and wrong.
Comment Number: 539814-00132
Received: 1/8/2009 9:54:12 PM
Organization:
Commenter: Joseph Szymanski
State: MA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

To me, DRM has little purpose in today's world. For games, it provides a difficult layer of problems for legitimate customers, but does little to stop people from illegally obtaining and installing a game. For music and video, it prevents what should be a standard process of moving content from one location to another. Unless DRM becomes "smart" enough to allow for movement of this kind among any type of device, it will be nothing but a burden. In many cases, DRM can actually prevent legal means of transferring copyrighted material, for example, to back up the media in case or failure or loss. In addition, multiple types of DRM have been know to cause damage to the systems they have been installed on. Sony had the rootkit fiasco, which even included using the rootkit to circumvent the DRM! SecuROM has had past issues of interacting poorly with software and hardware. Removing the DRM software is difficult, if not impossible in some cases. To sum up, I don't believe that DRM should be a primary used system for future content.
Comment Number: 539814-00133
Received: 1/8/2009 9:54:25 PM
Organization:
Commenter: Richard Riessen
State: MI
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Though I can appreciate the reasoning behind DRM in software as well as music, the sad fact is that it causes more of an inconvenience for legitimate users than it does for pirates. Pirates will always find a way around copy protection, they always have and they always will. I have been in the PC world pretty much since the beginning and this is the way it has always been. DRM is something that I have learned to live with, I have multiple computers and a couple of MP3 players that use the same iTunes account and my music does not leave those confines, but I know others that wish they could burn purchased music to MP3-formatted CD to listen to in their car stereos and cannot because of the DRM. Unfortunately, this results in a situation where legally purchased music cannot be listened to by the authorized consumer. Though my concerns are mostly with music-based DRM, I understand that the same situations exist for games and other software. In the end, again, it is the average consumer that gets inconvenienced because the pirate already has what they want and is already laughing at the companies that put the DRM in place.
Comment Number: 539814-00134
Received: 1/8/2009 9:57:22 PM
Organization:
Commenter: Alex Parkhurst
State: OR
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is anti-consumer and does nothing to stop piracy-- games and movies with some of the most stringent forms of DRM have the copy protection cracked at release (or before, in some cases). The only people DRM affects are the legitimate consumers of said products, and I strongly feel that DRM should be illegal, especially in forms where it infringes on the end-user's rights.
Comment Number: 539814-00135
Received: 1/8/2009 9:59:20 PM
Organization: Meteorological Economist
Commenter: Jeff Jarlett
State: NC
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

My opinion on what the FCC should do. There needs to be a balance between the rights of the consumer, and the rights of the corporation. Ultimately, the free market will decide this. However, the current situation is not a free market. Free Markets require even flows of information- this is known to any economist. Right now, software corporations use stealth, deception, and asymmetrical information that do not allow consumers to make informed decisions unless they are acutely aware. My idea: The intent of any legislation should not be to discourage DRM, but to allow for consumers to make an informed decision My suggestion would be warning labels on packaging or on the pages for direct download services, similar to warnings on cigarette packages The things consumers would need to know - The activation limits , whatever they are, if the activation window is longer then seven days. (So a 10 activations in a day limit is fine, but 10 in a year would have to be noted) - Any negative, or potentially negative effects caused by the installation of DRM software Also, any DRM system should be forced to have an option to uninstall the DRM with the uninstallation of the software. Such uninstallation shall leave no traces of the DRM system after uninstallation. -The DMCA should be amended to allow for circumvention of DRM schemes if a person has a legitimate license for the software that is still valid. Under no circumstances should circumventing the DRM be defined to invalidate the license, directly or indirectly. -Click-through agreements shall not be used to circumvent any of these provisions under any circumstanes, and shall never be defined as a valid contract.
Comment Number: 539814-00136
Received: 1/8/2009 10:00:03 PM
Organization:
Commenter: William Marlett
State: AZ
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is nothing more than a failed profit-generation technology that has been defeated a nearly incalculable amount of times than it has actually succeeded in its goal. It causes more grief to people who legally purchase the game and does absolutely nothing to combat piracy.
Comment Number: 539814-00137
Received: 1/8/2009 10:03:06 PM
Organization:
Commenter: E Mills
State: Outside the United States
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

It's frustrating to know that when I buy a movie, video game or CD, the content providers seem to think I'm only buying a license. When I purchase movies and TV series, I would like to be able to back them up on my home PC without violating the warnings on packaging and before the feature. Second to convenience of networked entertainment in my home, I circumvent DRM in order to enjoy what I have purchased without cumbersome warnings and ads included in many DVDs. It's not hard to do, but I would prefer if there were no DRM to circumvent. Pirated DVDs are better to watch because they skip the fluff added to retail products. The warnings included with DRM attack legitimate purchasing customers, which is very frustrating.
Comment Number: 539814-00138
Received: 1/8/2009 10:03:22 PM
Organization: 303 Software
Commenter: Matthew Jaffe
State: CO
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM places an unfair burden on consumers like me.
Comment Number: 539814-00139
Received: 1/8/2009 10:03:55 PM
Organization:
Commenter: Joshua Petrus
State: PA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Because of the piracy that plagues today's PC software industry, Digital Rights Management is a good concept - on paper. But in practice, it is little more than an inconvenience for consumers, if not a literal stripping of their rights to ownership of the media. Games with DRM still get pirated. It is not an effective obstacle to pirates. It is merely a nuisance to honest consumers and, depending on the level of DRM, a robbery of their ownership rights.
Comment Number: 539814-00140
Received: 1/8/2009 10:04:23 PM
Organization:
Commenter: Maust
State: GA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Greetings. Corporations, companies, and individuals have a right to sell their creations without having them copied and distributed, under the law. This is a right that I respect every time I make a purchase of a film, video game, or e-book. However, as a consumer, I have certain rights as well. Rights that, generally speaking, are blocked by Digital Rights Management as it exists today. Here are a few examples of what I mean: -I don't feel I should have to purchase a film multiple times, just to get it to work on a portable player or in a computer. -I do not feel that DRM rights management should be used to keep media from moving between different portable devices. The iTunes store, in particular, makes it incredibly difficult to move large collections of songs from their store to a portable device that is not an iPod. In many ways, this hurts their competition in a way that is not fair from a business perspective, it and hurts the consumer. -I do not feel that I should be forced to re-purchase a video game after a set number of activations, without adequate support to regain more activations. As a consumer, it seems wrong that I will lose the product I've purchased if I have a few computer failures or decide that my current machine cannot keep up with newer machines with more features. -I don't feel that the "copyright pirates" should receive a better product than the consumers. A person that downloads a "pirated" copy has all the freedoms above, while paying consumers have to go through a terrible ordeal to simply get their purchases to "work" sometimes. -I don't feel that it works. Let me cite a source here for you: http://torrentfreak.com/top-10-most-pirated-games-of-2008-081204/ Now, the video game "Spore" is known for it's extensive digital rights management. However, as you can see, nearly two million downloads of this video game have occurred. This is not a good thing. And I am not saying that I know the cause of it is the DRM. However, I can say that heavy DRM does not seem to deter piracy, and it does seem to cause terrible problems for those that legally purchase the product. And this leads to my next point... -It's annoying. Please. FTC. I understand that right holders have a right to sell what they own. But I also think consumers have rights as well, and they're selling us a broken product, that they break intentionally. Bad sectors on DVDs to avoid ripping, which can hurt playback. SecuROM, which in its most powerful form has proven to stay on a computer and cause irreparable damage to the registry and performance. It's bad for consumers, who just want to enjoy their purchases without being punished for the actions of a select few. It isn't fair to the consumer.
Comment Number: 539814-00141
Received: 1/8/2009 10:07:24 PM
Organization: checkyourhud.com
Commenter: Michael Kurz
State: NJ
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

As editor of the gaming blog Check Your HUD found at http://www.checkyourhud.com and active member of the gaming community, I would like to submit the following rules with regards to acceptable practices for DRM implementation. 1. Publishers shall allow no less than three concurrent installs of a given piece of software. Customers shall be able to deactivate these installs and reactivate them on a new system. 2. A hardware upgrade or an OS version upgrade shall not constitute a new install, and shall not nullify a current and active install of a given piece of software 3. Online authorization of software shall be supplemented with an alternate method in the event that the customer’s internet is down when reauthorization is required. 4. Online authorization shall be required no more than once per month for single player games. If the game has an online multiplayer mode the authorization may be checked more frequently, but only when the online multiplayer mode is used. 5. Online authorization servers shall maintain a 99% or better rate of uptime. 6. If online authorization servers are to go offline temporarily for scheduled maintenance, authorization shall be deactivated for the duration of the downtime. If the authorization servers are going offline permanently, the authorization shall be disabled permanently before the the servers are taken offline. 7. No DRM software shall run on a system after the product it is authorizing has shut down. 8. Customers shall be allowed a means of backing up their software installation files, either by allowing back ups of the physical media, or by providing a downloadable version of the software installer. 9. DRM software shall not interrupt normal operations of a PC. DVD/CD burners, antivirus software, and all other hardware and software shall continue to operate as they previously did after the DRM client is installed. 10. No malware shall be installed as part of a DRM client. This includes rootkits, and any and all types of spyware.
Comment Number: 539814-00142
Received: 1/8/2009 10:10:28 PM
Organization:
Commenter: Skyler Hawthorne
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I am of the strong opinion that the Digital Rights Management used by publishers, such as EA, is in strong need of removal--or at the very least, revisal--from video games sold to the public. Measures such as SecuROM, which limit the number of installations allowed per copy, effectively turn the physical material purchased into a temporary ownership. Situations will always arise in which games will need to be installed several times on the same machine, such as a hard drive reformat, or data corruption. Also, a recent DRM measure has been the requirement of an internet connection to activate the game. I cannot stress enough that it is simply ludicrous to require an internet connection to be allowed to play a game that does not require an internet connection for the actual gameplay. Besides the points above, all of these measures prove to be fruitless anyway. It has been shown repeatedly that DRM does nothing to stop piracy. Games are always cracked within days, if not hours, of their release. And so the pirates, whom they implement this DRM software to stop, get a better, DRM-free verison of the game--and they didn't even pay for it. In short, the present DRM measures have proven with each and every new game release to be completely useless in terms of what they're actually supposed to accomplish--stop piracy--and so do nothing more than create an unnecessary difficulty for the legitimate owners.
Comment Number: 539814-00143
Received: 1/8/2009 10:10:55 PM
Organization:
Commenter: Brian Kilkowski
State: MD
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Intellectual property rights have to be balanced against Fair Use, as well as against practical reality. This means the balance between IP protection and Fair Use has to take into account how much IP protection ( particularly, how much financial protection ) will *actually* be achieved, not some pie-in-the-sky wish for zero copyright violation. If that amount of actual expected protection is dwarfed by the level of Fair Use infringement, than the DRM in question shouldn't be sanctioned.
Comment Number: 539814-00144
Received: 1/8/2009 10:11:45 PM
Organization:
Commenter: Sean Renaud
State: NE
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

The idea of DRM is a good thought but useless. By implementing DRM technologies legitimate customers are being treated like pirates and thieves. The sad thing is generally the pirates have the DRM protection broken before the game even hits store shelves. A lot of DRM technologies are actually renting out their software by restricting the amount of times a user is able to install a game. This makes me want to never install the legitimate version of a game even if I buy it because when I pay hard earned money for a game I expect the game to be mine to play or even resell. Paying retail price for renting a game is simply an insult to the legitimate users. The fact that most of the DRM technologies aren't even laid out for customers to know exactly what they do is also disturbing. These technologies are running at extremely privileged levels on the PC that could have terrible consequences if the software was ever comprised. On top of these glaring flaws the DRM can't be easily removed. TO protect their game they're practically taking over private property that isn't theirs. I've actually avoided games with DRM on them.
Comment Number: 539814-00145
Received: 1/8/2009 10:12:32 PM
Organization:
Commenter: LePine
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Please enforce the need for companies to make aware the intentions and limitations of their DRM procedures elicitly to the consumer. The consumer has a right to know and be aware of exactly what they are purchasing before spyware or malware is unknowingly installed and use of the product is limited.
Comment Number: 539814-00146
Received: 1/8/2009 10:14:04 PM
Organization:
Commenter: Aaron Warren
State: OK
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I love idea of a company that works hard to produce a good game getting the profits they deserve. In the last few year I have dealt with things like having to have the internet to even install a game when at times I didn't have the internet, these are bothers but workable. Things that install programs in the background on my computer I am not ok with. This is my property and I feel that this is a blatant disregard for my property. When I uninstall things or want them off of my computer and they don't fully remove themselves to me that sounds like Malware. I don't like viruses. I hope that we can find a way like Valve's Steam to keep people from blatantly stealing but I hope we don't have a fiasco like Spore. I think that the people stealing PC games are ruining the overall experience for every one. I also think companies are naive thinking that a DRM is going to keep people from getting a work around.
Comment Number: 539814-00147
Received: 1/8/2009 10:17:49 PM
Organization:
Commenter: Isaac Rangel
State: FL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

broken down non tech English its simple.. DRM is a serious issue, not being able to install on multiple machines, also not being able to play the game YET its fully installed in the computer. look at it as having to use your original install disk for every single program on your computer from word perfect, Photoshop, ect. since they added the DRM restrictions i cant play my game on multiple systems say my lab top or home computer due to there limited install. Than after having a system error which happens to every computer late or early out of the box, get denied the ability to install also have to go threw customer service and explain what happened? for them to allow me to install the item, even tho i have purchased it. I treat my computers very well and have little to no errors. but they happen. sometimes having to reformat my computer due to a issue. Even the best Virus protection isnt 100% and sometimes there are compatibility errors per software/hardware in each computer. why should it matter if i want my dad to play the SIM 2, a simulation game on his computer if i bought the item? we can share cars, pens, video games on home systems but not DRM computer games. Most the times it encourages the borrower to buy the game/software. My Sims games a prime example. when they introduced DRM on an expansion pack various computers couldn't read its own disk saying "please insert the game" yet it was. DRM tells the computer if someones trying to copy a disk but end up messing up optical drives and staying in the system almost like a virus. If you were to research DRM anywhere they will break down the process better. how its pretty mush a hidden Virus that is very hard to remove even after deleting the original game that its 'monitoring'. DRM does very little to combat piracy and puts a strain on the consumer. limiting installs, driver errors, having to deal with customer service to prove to them your not using it for other reasons, limiting sharing ect. If i mass produce the product to sell on EBAY, than its a issue. if i let my 18 year old brother borrow it, than its sharing, He is my brother. No different than sharing a book or letting him drive my car.
Comment Number: 539814-00148
Received: 1/8/2009 10:18:03 PM
Organization:
Commenter: Zachariah Gonzalez-Belenki
State: NY
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

There is little to be said about Digital Rights Management except that it rarely works as it's supposed to. When it does work, it can only prevent you from using your paid for items as you want to- copying a song as many times as you want, for example. This shouldn't be allowed in the first place, but I suppose if you sign a paper saying you won't, then you shouldn't. But it doesn't always work. I hear more stories of Digital Rights Management software preventing people from using their paid-for and legally purchased computer games, music, and software than of DRM working seamlessly. DRM can often shut down certain programs from running, simply because it recognizes them as pirating software- which isn't always the case. Also, DRM so far hasn't stopped piracy from working. Pirated copies of the game Spore (whose DRM sparked huge debates) were available on the day that it was released. In short, if DRM did what it was supposed to with no fuss, then the argument would be a moral one- "How much can you watch me?". But DRM doesn't work like it should, it's highly noticeable, and it can often interfere with the running of your electronics. As such, it shouldn't be used at all.
Comment Number: 539814-00149
Received: 1/8/2009 10:20:11 PM
Organization: Lex PC Geek
Commenter: Steven Malis
State: MA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

To me (and many others) DRM is seen as punishing the legit buyers and inconveniencing the pirates. Almost always when DRM is involved there will be problems installing/running the game, glitches/bugs/crashes due to DRM, etc. Pirated versions have the DRM removed! They get the better product! And don't forget how ineffective DRM truly is. Look at Spore: pirated days before it was even released, DRM removed and ready for illegal downloading. Companies need to do something about pirating, but DRM only punishes the people who actually buy the game. As for music, I believe this sums it up nicely: http://imgs.xkcd.com/comics/steal_this_comic.png
Comment Number: 539814-00150
Received: 1/8/2009 10:21:55 PM
Organization:
Commenter: Michael Rollins
State: FL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

The Digital Rights Management movement that is becoming more and more prevalent in the world of electronics hardware and software is putting a stranglehold on the consumer. Software companies, in particular are not afraid of putting harsh restrictions on products that many people pay good money for. To a point, this means that we never actually own the software itself. What we do own is a lease on the software until certain conditions are met that terminate the ownership. For instance: most computer game software that has DRM will allow the owner to re-install the game no more than three times until the software expires and the user is forced to pay retail price on the game to re-activate it. You will also lose one of the three installs if there is a major hardware change in the computer system that supports that software. This is not the way to protect intellectual property. I'm afraid that if the DRM continues as it does, it will only become more restrictive and controlling as time goes on. It seems perceivable that some day, one company's software could restrict or deny the use of a rival company's software. The more and more that I deal with DRM, the more that it seems like reality.
Comment Number: 539814-00151
Received: 1/8/2009 10:22:20 PM
Organization:
Commenter: Alexander Harper
State: WA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Digital Rights Management, also known as DRM, is the single greatest threat to the digital revolution occurring in America today. In this day and age, DRM permeates every kind of digital media. DRM is on purchases made through the popular digital music service "iTunesquot; , it is present on many popular video game titles,, and it is present in eBooks, books purchased and read electronically. However, the actual benefits of DRM software have not been proven. In fact, due to the negative public perception, and ineffectiveness of DRM software, several video game publishers, such as Stardock (www.stardock.com), and Good Old Games (www.gog.com), have completely eliminated DRM from their products. Others, such as Apple, the proprietor of iTunes, have announced their intentions to remove DRM from their products, and offer DRM removal services for a fee. However, you, as members of the committee investigating DRM, know all of this. What you do not know is that DRM limits the freedom of legitimate consumers, all in the name of stopping piracy, which it most certainly does not. A cursory glance at a BitTorrent website reveals many easy ways to circumvent, disable, or outright remove DRM from protected products. DRM has been linked to the failure of disk drives, the corruption of vital system files needed for regular operation of a computer, and other failures. DRM software limits the freedoms of legitimate consumers in many ways, the most common of which include limiting the number of times a product can be installed under a certain passkey, the requirement for a disk to be in a drive to use software when the program does not require files from the disk to run, and refusing to allow a program to run if a certain program is installed on a computer. A recent example of a program limiting the number of installs arbitrarily is the video game Spore. Spore utilized SecuRom DRM, developed by Sony, to limit the number of installations that could be performed before the software locked a user out of further installations. This method not only insults legitimate consumers by treating them like criminals, but it also creates a gigantic hassle for legitimate consumers by requiring them to call Technical Support, or forcing them to download tools that are granted deep access to a system, and which may be unreliable. In addition, this method, which almost always utilizes the SecuRom software suite, installs a program called a "rootkit" which hides the program, and its operations on a system. Rootkits are common features of internet worms, viruses, and trojan horses. A program which uses such techniques surely should not be trusted with unfettered access to our computers, yet it is allowed such access on a regular basis. However, not all DRM is unneeded. In programs such as Adobe Photoshop, there exists a DRM feature intended to stop multiple uses of the same product. This is the necessary sort of DRM, needed to accurately report usage statistics based on which keys are reporting, and provide accurate and dedicated support to products consumers are actually using. In conclusion, DRM is the greatest threat to the Digital Revolution. I had hoped to elaborate more on my points, but the character limits imposed by the program the committee is using does not allow me to do so. I trust the committee will take the appropriate course of action and recommend that DRM be regulated tightly, to end the oppressive tactics of such organizations as the ESA. MPAA. and RIAA in deploying DRM.
Comment Number: 539814-00152
Received: 1/8/2009 10:25:14 PM
Organization:
Commenter: Krystian Niepsuj
State: IL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

To make it quick and short, the biggest issue with DRM is that it is almost completely ineffective and works backwards. I understand that DRM is there to protect certain aspects including someone's work. However, all it does is make the consumer pay. This is the wrong way to go about this. There is a bigger advantage to stealing the product or pirating software because there is no DRM that way. The only way to curb piracy is to give consumers the advantage back. Sometimes I think that piracy is Adam Smith's invisible hand guiding the market back to equilibrium. Most companies that introduced DRM never lowered the price, never made any other effort to increase the value of their product. A great example is the securom effect. Securom is an anti piracy system that EA includes in many games, one for example being Red Alert 3. Securom limits the amount of times you can install a product, it also requires online activations. A pirate on the other hand can just download said game and thanks to modern piracy efforts can enjoy the product hassle-free. No activations necessary, you just install and play. What about the case of HDMI 1.3 and HDCP. HDCP is a DRM system included in most modern High Definition televisions and media players (blu-ray). The problem is early adopters of HDTV's do not have HDCP on their television. Eventually they will run into the problem of spending money on a HD Media player only to find that because their TV does not contain the HDCP the movie will now play at SD resolution rendering all of their purchases worthless. A pirate on the other hand would have no problems, since he would have found a rip of the movie with HDCP, the DRM component, removed. The economy is steadily decreasing, now is the time for manufacturers and developers to listen to the consumer. If this situation is to change you HAVE to create value for the consumer. This is a new era of technology and manufacturers and developers are still imposing a tired old model. This needs to change. Pricing structures need to change and so does the way these big companies think. Once companies realize this and change everyone including consumers can/will profit.
Comment Number: 539814-00153
Received: 1/8/2009 10:25:33 PM
Organization:
Commenter: Jeff Clark
State: OH
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM, while created with the intention to protect copyrighted materials, ultimately punishes the consumers who actually purchase the products. DRM is more of a deterrent to the purchase of material then anything else. I personally feel that adding DRM to music, for example, constricts the users ability to enjoy the music. Copyright protection ends up being more of a hassle to the buyer, then an understandable hurdle. In terms of games, PC games in particular, I find myself increasingly frustrated in the newer DRM technologies that are arising recently, SecuROM being the most notable. I find myself avoiding re-installing MY OWN GAME. I quite often restore my system to clean the registry, and the idea that I am hesitant to reinstall a game that I payed to hold private rights to is quite astonishing. My 3 install limit, has made me afraid to reinstall the game, and while I understand that it is a soft limit, I still find it to be a hassle. Now the thing that aggravates me even further is the naivety of the industry. DRM has turned into something that punishes the consumer and rewards the pirate. Hackers can circumvent DRM and pump out a clean version in 24 Hours. So I have two choices, I can buy the game, spend fifty dollars on it, install it, and run into restrictions and hassle, or I can download a cracked version of the game FREE...a WEEK before its even released, with no restrictions what so ever. The draw of pirating a game is rising with the technology generation, the price of legitimate games, added with the ease of downloading the pirated version makes this an extremely easy choice. Now I am not promoting a completely unrestricted software install, the failures of that can be seen with a game like "World of Goo", but the combination of registered CD keys and traditional protection of that sort are completely understandable. For a perfect system of Copyright Protection look to Steam. Steam gives a USER the right to play a game on any system he/she chooses. Install it remotely and enjoy. DRM's main failure is that it links the media to SINGLE piece of HARDWARE. The average user switches hardware at least every three years, and own multiple systems. THE CONSUMER is the person who has purchased rights, not the system. So in summary: DRM has failed because of it's disregard for the consumers, DRM does not promote purchase, Instead it hurts the very consumers who actually want to buy the game I find myself not purchasing games because of this very fact. So by that very fact that I am one lost customer, DRM has failed terribly. but here's the fact. I'm one among tens of thousands
Comment Number: 539814-00154
Received: 1/8/2009 10:26:33 PM
Organization: University of West Florida
Commenter: Joe Plante
State: FL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is a pretty complex issue. Software publishers want it to help lower piracy, but at times, it gets in the way of enjoying software. Sometimes it gets intrusive where it hurts parts of Windows, and other times you just want to play a file on whatever platform you want. Movie studios definitely like having it on DVDs and Blu-ray, but as you know with DVD, that copy protection has been bypassed. I like maintaining a stable Windows PC, and when I install a game, I worry that the stability could be affected by a piece of DRM. However, not many DRM schemes have worked, and in many times on the PC, has been circumvented. So, some people use the argument of "it's safer to pirate the game than to buy a copy." Some DRM tracks information about your PC to decide whether or not to allow you to play a game. Usually, it's minor details like your CPU and motherboard, but we can never be sure unless you know how to reverse-engineer the executable. DRM used to be worse than it is today. Sony BMG once had CD copy protection, and it could get into the way of using the DVD drive on your computer. Some CDs even had DRM that damaged computers, like the case of Celine Dion CDs damaging Mac firmwares. http://hardware.silicon.com/desktops/0,39024645,11033357,00.htm DRM also could hurt PC game resales since games like Bioshock allow a limited amount of activations. Activation is basically a program on a PC connecting to a server online to ask permission to operate. One worry is that companies may see this as an opportunity to lower used game sales, since many companies don't make any profit on them whatsoever. Anyways, thanks for taking the time to read my concerns. If you have anything to ask me, feel free to contact me at .
Comment Number: 539814-00155
Received: 1/8/2009 10:28:25 PM
Organization:
Commenter: Mark Wolfe
State: PA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Greetings, As an avid video game enthusiast for most of my 45 years, I have witnessed the various stages of the video game industry and the various attempts taken by some companies and publishers to try to stem the tide of piracy which I am sure we can all agree, hurts the economy and the very industry we "gamers" derive so much joy from. While I do not have any good answers as to how to better circumvent piracy, I can tell you that DRM, the current method of locking discs so as to make it just a little bit harder to pirate a game or program, only succeeds in harming the paying customers and causing harm and frustration to those who legally obtained the game or program in the first place. The internet is full of consumer anecdotes as to how DRM has caused them problems, no doubt the reason for this FTC inquiry. Meanwhile, pirates of software are seldom stopped or even slowed in their activities and to date, no game or software that has employed DRM has kept the software from being pirated. We have to ask ourselves, who is being harmed here, the pirate or the consumer? I think the evidence points to the latter and that DRM needs to be put to rest and that no hinderances on using software be put in place that in any way keeps the consumer from using said software and that other measures, or NO measured need be employed to stop piracy, since it is obvious there is no way to stop it under current legal methods. I do hope that this letter is taken in to consideration. Thank you for taking the time to read it. -Mark Wolfe Pennsylvania
Comment Number: 539814-00156
Received: 1/8/2009 10:28:40 PM
Organization:
Commenter: Vinnie Pai
State: NY
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is only going to further cripple media (such as music, movies and games) in the future. Already, it limits the buyer's rights, causes software/hardware incompatibility and increases piracy (mainly because of users who want to avoid the previous problems). While DRM is, in a way, "necessary", it only hinders the goal creators are trying to achieve in reality. Eliminating DRM will definitely help solve some of these problems, and decrease the amount of problems and criminal activity caused by media distribution today.
Comment Number: 539814-00157
Received: 1/8/2009 10:29:05 PM
Organization:
Commenter: Zack Benjamin
State: OH
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I feel that the recent "overuse" and "abuse" of DRM by companies recently has been taken too far. In some cases, DRM can be unobtrusive to the customer however it is sadly a burden the majority of the time to the paying customer, while the pirate who has illegally downloaded such a product does not have such limits placed on it. DRM is especially annoying when placed on any form of music or video, since this basically locks down the number of devices which it can be used on. If someone legally buys and pays for a song online, they should legally be allowed to put that song onto whatever device they choose to and then be able listen to it without the limits of DRM saying it can only be played on certain or "certified" devices. In terms of computer games, excessive DRM can severely limit the functionality of a purchased game. CD checks are okay but when companies take it further with garbage like online activations and limiting the number of computers that the game can be installed to, it's hard to blame people for downloading the superior pirated version which has no such annoyances. When someone legally buys a computer game, they should have the right to install it and re-install it over the years as many times as they see fit. The fact of the matter is that excessive DRM scares away potential customers and encourages piracy. Even the absolute best protection that companies can think of to protect their games and software is broken within a couple of days by hackers and pirates. This negates any effect DRM would have against piracy. Penalizing the consumer of such products with lengthy installation procedures or limited activations does not help to curb piracy in any way, and only make's the customer's use of that product to be more aggravating. Many people simply avoid purchasing products with such excessive DRM, and its hard to justify buying digital music that is crippled in functionality as the result of some half-baked idea that it is somehow going to prevent piracy. The only DRM that is ever really necessary I think is the absolute simplest, most unobtrusive technique that is transparent to the consumer. Examples of this are CD-checks, which prevent someone from installing a game onto every computer and being able to play it simultaneously, and also Valve's Steam Service. Steam I think is a shining example of DRM for computer games done right. You can install your purchased games onto as many computers as you like, however you can only log onto your account in one location at a time. This also lets you log into other computers away from home with steam games installed, and then play them by using your own account. Since you are allowed to download and reinstall the games anywhere and as much as you desire, the service works. Music and Video should ditch DRM altogether, because when someone buys the song, they should actually be buying the song itself for their use in any form, not some "license" to the song that allows them to play it only under very rigid, specific conditions. I think the only exception to this is subscription based song services that let customers download an unlimited number of songs for one monthly fee, a case in which the songs are only playable when the subscription to the service is active. The same applies to video.
Comment Number: 539814-00158
Received: 1/8/2009 10:29:22 PM
Organization:
Commenter: Christian Cox
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

The main problem with DRM is that it hurts legitimate gamers that buy games. Also, EA (large gaming company notorious for using DRM) is very secretive about placing DRM and SECUROM in their games-info on the box might be nice.
Comment Number: 539814-00159
Received: 1/8/2009 10:30:57 PM
Organization:
Commenter: David Johnson
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I think DRM is about balance. In the real world... people don't walk into stores and steal products. There is a fear, a conscience, and clear and present consequences that will be enough to make most people not steal. On the internet, the same does not hold. Even most of those that are creators of copywritten material pirate music or other entertainment. This is compounded by the elimination of geographic and cultural borders that the internet provides. Those that don't share the ideals, or otherwise have no love for America will have no sense of obligation whatsoever to pay for media. I think there should be some artificial barriers introduced, like DRM to provide a substitute real world deterents. Of course, the resourceful will always find ways around protections. In general, as long as the majority participates in legal practices, and the violators remain a majority... the goal has been acomplished. But when technology is moving so fast, that the tech savvy can find new ways/programs/website to distribute media, and make it popular to do, a more systemic approach will be necessary. The criteria that I would put forth for DRM are the following. It should be non-invasive. It should be effective (broken/easily bypassed DRM is no DRM). It should be global. It should be as enjoyable as Non DRM alternatives (Zune suffers because it's nicer to get mp3's than deal with their only play 3 times) DRM technologies that have been started, for instance Zune and Apple that restrict music playing have had mixed results. Zune's limit of 3 shares with friends (which is one of it's major selling points) emphasizes limitations and gives the user a "why bother" feeling. While Apple's "you bought it, our servers know that, you can redownload it later" is more sucessfull. The user feels like they have a benefit... even though DRM exists (auto backup of their purchased music). Look at other anti-policing methods that have been successful. Blizzard's World of Warcraft enjoy's very little piracy. Because it's not really the bits you are buying... They have servers that authenticate you, and allow you to enjoy those bits that were on the disc you purchased. The disc by itself is worthless/meaningless. Other videogame companies have seen the success of this and are moving in this direction. Valve's Steam is a similar success story. You never actually have all the data that makes up the game on your hard drive. You have a lot of it... but when you connect to the "media" the completion bits are sent to you. Could this approach be used for films and music? It would be tricky, as mp3 players aren't connected to the internet all the time. And with music... there's always way's to capture the results and turn them into a non-drm version. Also, look at youtube for another model of copyright protection. A self policing community. Where the users can flag material as lewd or infringing. I'm not sure how this relates to DRM... but I think all approaches should be examined. The current form of DRM is weak at best, and new approaches are needed. Perhaps all hardware vendors needs to be on board. Perhaps the only way to eliminate DRM cracking would be to have all consumer electronics expect the media to be in a secure, properly paid for format.
Comment Number: 539814-00160
Received: 1/8/2009 10:31:51 PM
Organization:
Commenter: Welliver
State: OK
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I don't believe that DRM has any real effect on reducing the amount of piracy a game gets. I frequent some private torrent sites and I consistently see games up either the day before release or very shortly after, with full working cracked .exes and other workarounds. On the other hand, I personally have experienced DRM problems when buying software legally as a consumer, in some cases so severe I was unable to boot the product. And of course, software cannot be returned to the store, so that is cost that I must eat.
Comment Number: 539814-00161
Received: 1/8/2009 10:33:17 PM
Organization:
Commenter: Daniel Garcia
State: Outside the United States
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Hello, As an American citizen living abroad, I felt my duty to chime in on this issue. Yesterday a friend of mine brought to my attention that the HDMI spec is changing. Seems the movie studios in their zest to DRM the video, forgot about the audio. So now they are reintroducing DRM to the audio component which basically means that people who own Blu-ray players, Playstation 3's, or any DVD player with and HDMI output are now screwed. Also, in case you were niot aware of it, pirated Blu-ray movies have been released at the same time or earlier as their commercial counterparts so DRM is not even stopping that but it is inconveniencing consumers. Let me cite another example, SPORE by EA Games for the PC format. The first release had so many bugs some people tried to reinstall it multiples times as it kept becoming unplayable, but of course they were stopped from doing so because of the draconian DRM. I know several PC gamers who buy their games then immediately proceed to download a pirate copy specifically to avoid the DRM. The only thing DRM really does in this instance is prevent people from reinstalling a game they legitimately bought after the game crashes so badly that it won't run anymore. The other thing it seems to do on some extreme cases is compromise the operating system with rootkits making it more likely for viruses and trojans to compromise a system which just brings productivity down. Also, several online music providers have started offering music without DRM and saw their sales increase. Apple made the same move this past Tuesday to drop DRM from their music files and charging a bit extra. The obvious reason for the increase in sales is that consumers don't have to worry about which device supports the DRM du-jour and can actually enjoy the product they bought. DRM doesn't stop the pirates as they continue unabated, all it really does is cause headaches for consumers and increase support costs. It is absolutely ridiculous. Sincerely, Daniel.
Comment Number: 539814-00162
Received: 1/8/2009 10:36:06 PM
Organization:
Commenter: Brendan McCarty
State: PA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is a horrible idea, and since being put into practice has greatly increased reasons for pirating music and movies.
Comment Number: 539814-00163
Received: 1/8/2009 10:37:09 PM
Organization:
Commenter: Luke Bittner
State: MD
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM technology has been the subject of much debate for many consumers of digital media. The reasons for the introduction of these technologies are widely known; there's no need for me to reiterate them. The issue today is the impact of DRM on the paying consumer. Simply put, while there exists a significant number of people who want to get their digital content for free, the majority of consumers do not believe in getting something for nothing. The popularity of the iTunes music store, along with other legal music download services, proves this. Problems start to occur when DRM starts to hinder the Fair Use rights of the consumer. Your average digital media consumer is not interested in distributing copies of his newest DVD across the internet. He just wants to have it available for viewing on his iPod. When the DRM prevents this, Joe Consumer is forced to download a digital version from the internet. This is a prime example of why DRM is an outdated paradigm. It focuses on the prevention of losses from non-paying individuals, while ignoring and under-serving the forward-thinking, paying customer. It's Business 101 - serve the needs of the consumer, and your company will make money. By not keeping that as the primary goal, many media producers and distributors are alienating their customers. In PC games, DRM (most often Securom) is used to ensure that the game is a legitimate copy. Most gamers do not have a problem with DRM, especially when it provide value and service to the user, not just to the publisher. DRM "services" such as Steam are a good example. Steam is a robust DRM program, and like any DRM program it imposes some inconveniences on the player, but it provides so much additional value that players do not mind it. The bottom line is this: DRM should be a partner to the consumer, not an enemy of the consumer. Content companies should work with distribution companies to make DRM technologies transparent, simplified, and most importantly, desirable to the consumer.
Comment Number: 539814-00164
Received: 1/8/2009 10:38:11 PM
Organization:
Commenter: Joseph Kapp
State: FL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I believe that DRM on games is useless. Even with DRM, pirates still pirate the game, and that just leaves the people that actually bought the game with a obstacle. With dome DRM, such as Securom, you can only install the game so many times then have to contact the company to allow you to install the game again if you go over the limit. This is ridiculous. If I pay for the game, I should have the right to install it as many times as I want. And also when you uninstall the game, the DRM program still remains on the computer and it is just junk sitting there. CD keys are enough, no DRM programs.
Comment Number: 539814-00165
Received: 1/8/2009 10:40:05 PM
Organization:
Commenter: Janiszewski
State: WA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I have a lot to say and only 4000 characters to say it, so I'll try to be brief. In 2008, I bought the game "Mass Effect" for the PC. My PC is only just good enough to play the game, so the performance of the game is low. I decided that I was going to hold off until my next PC to continue playing it. Afterward, I was informed that I was not allowed to install it more than a few times, or I would have to buy a new copy of the game. As it is now, the game is taking up 10 Gigabytes of my hard drive and I'm not playing it and I can't uninstall it because I don't know if they will release a revoke tool or not. If I uninstall it before a revoke tool is released, I will permanently lose one installation. Needless to say, if I was careless and uninformed, the money I spent of the game will end up being literally flushed down the toilet because I eventually wont be allowed to install and play the game. This is not fair. I understand why companies feel they need DRM. Piracy is a big deal, and giving away copies of a game is bad for business. However, if I wanted to, I could illegally download the game for free, and never have to worry about running out of installations. Where is the incentive to actually buy the game? I can pay nothing and get a better product, or I can be an honest person and get treated like a criminal. This is not fair. DRM comes in all sorts of forms. Music and downloadable content for console games also are restricted by DRM. Mostly, this is OK, because once again, letting people give away free copies is bad for business. The problem is, with consoles and iPods and such, if the device breaks, you can't always get the content you purchased back. When my Nintendo Wii broke, I sent it in for repair, and when I got it back, I couldn't use all of the features I had before it broke, because I was now officially using another console. Similar things can happen with the Xbox360 and PlayStation 3. These are just issues that *I* have come across, and I do my best to be an informed consumer. Not everyone will be as conscious of the limitations in the products they purchase as I am. Given the current trends, I could easily see DRM becoming more and more restrictive to the point where a consumer no longer owns the product they purchase, but have rights equal to that of some one who rented it instead. I'm afraid I don't have any great solutions to offer, but I would recommend creating restrictions on how restrictive DRM is allowed to be on a product. The easiest solution would be to just ban DRM, because I believe that products will be purchased if they are worth purchasing. Internet pirates will always be around, and punishing honest consumers is inexcusable.
Comment Number: 539814-00166
Received: 1/8/2009 10:41:09 PM
Organization:
Commenter: Christopher Drouin
State: ME
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I have numerous issues with the use of DRM and similar technologies used to secure or lock software and digital media. DRM is frequently used to impose restrictions on standard fair use and consumer rights that would be available for physical goods. It is usually difficult, if not impossible, to re-sell DRM-locked software or media. It is similarly difficult or impossible to time- and format-shift such content. Most worrying off all is the prospect of DRM-locked content "going dark." This has already happened multiple times (see Yahoo! Music and MSN Music for examples): the content provider switches technology or goes out of business, leaving its consumers without access to their purchased media. In some cases the companies involved have relented following public outcry, but they are not presently legally obligated to do so. Finally, DRM technology has been known to cause malfunctions in consumer hardware and software. Sony's infamous "rootkit" DRM software, distributed on certain music CDs, created large security holes on the computers onto which it automatically installed itself. The StarForce software DRM system has been known to cause hardware malfunction issues with a variety of computer configurations, as well as degrade overall system performance. In light of these circumstances, DRM appears tremendously undesirable from a consumer standpoint. There are non-restrictive content protection measures available to content providers, such as digital watermarking (where identifying information on the purchaser is interwoven into the content data, allowing companies to trace pirating leaks without restricting use). The music industry has voluntarily moved away from DRM over the last year or so - both Apple's iTunes store and Amazon's MP3 store now offer a full selection of DRM-free music. The software and movie industries have not, however. I would at minimum strongly recommend a mandatory full disclosure of DRM restrictions and potential side effects alongside information and advertisement for DRM-locked software and media. In this way, the presence or absence of DRM restrictions becomes a selling point to the consumer, ultimately promoting fairness, competition, and consumer rights.
Comment Number: 539814-00167
Received: 1/8/2009 10:48:29 PM
Organization:
Commenter: Rory Wilkins
State: NJ
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Piracy is a serious issue, and when you can steal and distribute something without physical form that problem balloons. However, the technologies used to combat piracy must meet certain criteria: 1) They must allow the rightful purchaser to access their property in perpetuity and at any time. 2) They must actually prevent piracy, nothing available now stops people from pirating games. 3) The would-be solution must not create an overly large burden to legitimate users. You create pirates when you make legitimate software so difficult to use that its easier to steal it with the safeguards removed. It is already a challenge to get PC games to work in the first place; adding hoops to jump through only makes stealing the game *more* appealing to those that would have otherwise bought it. 4) Unless driven to piracy (see #3) most people who pirate games... are going to pirate them. There are hundreds if not thousands of people that hack the protection on software compared to the few programmers dedicated to writing those protections. No protection isn't the answer but simpler may be better in this case.
Comment Number: 539814-00168
Received: 1/8/2009 10:49:27 PM
Organization: None
Commenter: Alan Ellis
State: Outside the United States
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is ruining the pc game industry. To install a game on more then one pc when you may have more then one you have to purchase the game more then once thanks to DRM. I for example have 4 computers and two laptops in my house. If i wanted to play the game on more then one then i would have to purchase it 5 times. Or in some cases maybe 2 or 3 times because of some company's allowing 2 installs. I believe that this is wrong and unreasonable. DRM also is basically spyware because it logs details on your system which it has no right to. If a game has DRM then i refuse to buy it.
Comment Number: 539814-00169
Received: 1/8/2009 10:50:34 PM
Organization: None
Commenter: Brendan Meehan
State: Outside the United States
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I haven't looked in to this in a big way, and don't play games on my PC too much these days due to it's poor specs but I can't see the point in software that only hurts the people who do actually spend the money to buy a product. Anyone who doesn't want to buy it, will pirate it regardless and have a nicer experience by doing so, and it seems to me that if anyone is on the fence on the decision in whether to buy a game or pirate it - DRM will probably push them to the wrong side.
Comment Number: 539814-00170
Received: 1/8/2009 10:50:44 PM
Organization: None
Commenter: Mike Nunziata
State: NY
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM, in most circumstances, ultimately serves no purpose beyond reducing the value of the product while increasing the value of the illegally obtained alternative. The more restrictive DRM is, the greater the extent to which it could be considered a implicit encouragement for illegal activity. It's not complicated. A DRM-protected music file is locked into a specific format and can only be played on one device, which is often required to be of a specific brand. An illegally downloaded song can be converted into whatever format is most convenient and played on any device the consumer happens to own. Even without considering the money saved, music piracy is still a vastly superior option to legitimate purchases. The situation is even worse with computer games, the DRM attachments for which often behave in ways completely indistinguishable from malware.
Comment Number: 539814-00171
Received: 1/8/2009 10:51:51 PM
Organization:
Commenter: Salomon Fuentes
State: TX
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

With regards to Digital Rights Management in the computer gaming industry there are several issues that are troubling to me as a consumer but foremost is the slippery slope that could mean other mediums such as movies and digital video recorders for instance. As is people who buy and use PC games for the most part do not care about DRM and are largely unaware as to what they are installing onto their computer (in regards to SECUROM a program that cannot be uninstalled without digging into the registry) as well as the fact that in many instances they will only be allowed to install the game a few times. However if the same method of "copy protection" were to be applied to DVDs, Blu-Ray discs, and on DVRS, people would not stand for this. In other words if we give game publishers the green light to use such strict DRM, what is to stop other copy right holders from allowing users to watch a movie they own a limited amount of times? In effect it would nullify the purchase as a rental, which is what many DRM games are today. One game, Mass Effect by Electronic Arts, forces the user to activate the game online, installs Securom, and only allows 3 installs/activations which cannot be undone. I personally respect the rights of copy right holders to want to protect their intellectual property but disagree with how they are doing it. Not only are they attempting to combat piracy (which is fine obviously) but they seem to be destroying the resale market. Game publishers do not implement this kind of DRM on console games like those on the Xbox 360, so there is obviously a double standard. Furthermore their attempt to combat piracy, while laudable is not working as DRM is increasingly an excuse for people to steal games and more people than ever today pirate games. What I would like to see is finding a middle ground. The Valve gaming company uses STEAM to activate a game. It requires an online check of the purchased game every time it starts up but allows for infinite installs. Only one computer at a time can play the game so it is fair for both the copy right holder and the game user. If all company's used STEAM or a variation of it, there would be no issue whatsoever. People are going to pirate games until their is a full proof way to prevent them from doing so. In the meantime though gaming companies should try to find a solution that does not penalize legitimate buyers and sets a double standard. Thank you for your time.
Comment Number: 539814-00172
Received: 1/8/2009 10:53:07 PM
Organization:
Commenter: Jeff Nichols
State: NY
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

As someone who enjoys PC gaming, I am strongly in favor of the IDEA of DRM on games-- I want PC game manufacturers to make all possible profits so that they continue making games for my platform of choice. However, most DRM solutions today simply reduce the value of the product through limited activations (in essence, making your purchased game a rental), by forcing you to have your disk in the drive, etc. Those who simply decide to steal the game will not have to deal with any of these problems. To be blunt, the pirated versions of a game, even if SOLD for the same price as the original version, would be worth more. DRM is silly, because hackers will always find a way to crack it, and in the mean time, it provides impetus for people to pirate a game. Many people I know buy a game, only to download the pirated version because it works better. I believe DRM such as EA has been using, forcing a limited number of game activations, misses the point. Valve's Steam, on the other hand, is a robust DRM scheme, but provides value to PC gamers beyond the pirated versions. Pirated versions of games cannot be done away with; but they can be competed against. Services like Steam compete successfully against pirated versions, while DRM-schemes like Securom detract from the game's value. Moreover, DRM like Securom puts a rootkit on people's computers that they can never remove, even when the game is uninstalled. This is inconceivable and the FCC Should ban this practice.
Comment Number: 539814-00173
Received: 1/8/2009 11:02:42 PM
Organization:
Commenter: Sean Welch
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

When I purchase a product from a company, I should own that product and be able to do what I want with that product. The product should not also interfere with the interworkings of other products from other companies or individuals. DRM in its current format is bad and needs to be removed or revised to give users full control of the products that are purchased.
Comment Number: 539814-00174
Received: 1/8/2009 11:04:30 PM
Organization:
Commenter: Anthony Halderman
State: OR
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

The biggest problem with DRM has remarkably little to do with piracy. The issue is that the current implementation of DRM punishes only those who will not pirate software. If I wanted to, I could go hit the Pirate Bay, which is not governed by any of the same copyright laws as America, and get cracked copies of anything within days of its release. DRM does no prevent this, because it is one small company versus millions of hackers all over the world. Even if the Pirate Bay is shut down, a similar site would crop up in some other country with different laws. From a legal perspective, DRM is a violation of several longstanding copyright laws all by itself. Books have always followed the first sale doctrine. If I buy a copy of Cryptonomicon, I can sell it or give it away as much as I want. I cannot, however, copy it. If I buy a copy of Spore, it only allows for a few installs. I can no longer exercise my right to first sale because EA believes that it retains all of its rights to the physical container that holds their IP. This is far different than distribution over the internet, which usually is copying, and is not covered under the first sale doctrine. Yet this form of DRM serves no purpose to restrict an illegal act. It is nothing but a way to make consumers buy more stuff. Software companies have not faced the realities of international business and law. There will always be a place where those who steal data can hide. And yet, those companies have chosen to battle the pirates with techniques that harm consumers and do not stop pirates at all. This is a terrible idea. Further, it encourages piracy. I would sooner steal music than buy it on iTunes where someone can track me. I would rather steal Spore than buy it because if I upgrade my hardware it won't work anymore. And yet, I will purchase digital downloads from MC Frontalot and Jonathan Coulton who use no DRM. And I gleefully dropped 50 bucks on Fallout 3, because it has no DRM. Theft cannot be deterred by making consumers angry with the providers, while those same consumers have an unlimited ability to steal that same product.
Comment Number: 539814-00175
Received: 1/8/2009 11:05:18 PM
Organization:
Commenter: Justin Blake
State: FL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM has never been much of an obstacle for pirates. All it does is hurt honest consumers, preventing them from truly owning the media they purchase. If anything, it causes more people to pirate software and media out of spite or sheer frustration. I've been there. I've been burned by DRM before, and have opted not to purchase DRM-protected media since. It's a whipping boy situation. Punish the innocent to deter the guilty. The innocent suffers and the guilty laughs it off and continues their dirty deeds. There are always going to be pirates. Treat honest consumers like pirates, and they will become pirates. Treat them like honest consumers, and you won't lose them. You may even gain new ones.
Comment Number: 539814-00176
Received: 1/8/2009 11:07:58 PM
Organization: BoxOfSpoons
Commenter: Samuel Carlson
State: WI
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I have been gaming since I was very young and have experienced various forms of DRM over the years. As a consumer I find DRM very annoying, especially when I don't realize it has been implemented till I read it on a website like Engadget, Kotaku, etc. This steers me away from these games (a recent example being Spore). I feel that companies implementing DRM should be forced to clearly state the type and details of DRM placed on their game, in a clearly stated area on the game box. However, I don't believe DRM should be illegal or controlled necessarily because I feel that is a liberty these companies should have, but the fact that it can be forced in sneakily (like StarForce, sigh...) is just unacceptable. I think having DRM gives people more a reason to pirate the game rather than purchase it.
Comment Number: 539814-00177
Received: 1/8/2009 11:10:38 PM
Organization:
Commenter: Carrie Krueger
State: PA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I have no problem with game companies trying making the money they deserve. However when the DRM treats me like a criminal by installing software I don't want, preventing me from making back ups for my own use or limiting how many machines I can use software I purchased.
Comment Number: 539814-00178
Received: 1/8/2009 11:11:11 PM
Organization:
Commenter: Collazo
State: FL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is the single biggest barrier to entry for the digital economy. I recognize that DRM implementations go from draconian to reasonable, but in the end, the customer is always at the mercy of the issuing company. I am not willing to part with hard earned money for a "good" over which I do not have control, and can lose access to it at any moment for any number of reasons over which I can't do anything about. Furthermore in the case of PC software, DRM is akin, and sometimes even more dangerous than a virus. Securom comes to mind inmediately, as the reason I was never able to enjoy SPORE from Electronic Arts.
Comment Number: 539814-00179
Received: 1/8/2009 11:14:25 PM
Organization: Student
Commenter: Andrew Schnellback
State: Outside the United States
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Ive been paying attention to the constant back and forth between DRM using companies, the consumers who find themselves not able to play their games and the game pirates who seem to easily bypass all the DRM techniques there are to date. My one friend recently purchased a game that I also purchased, the game is Battlefield 2 from Electronic Arts and DICE. He bought his copy from the Wal-Mart in our town and when he went to install the game it asked for his CD key and it worked fine. He then went to install the expansion packs that came with the "Complete Collection" but it said that his registration code was already used up. The game was brand new and still in the protective sealing straight from Wal-Mart, when he contacted EA for support they simply told him to purchase a new registration key. Why should he be forced to pay an additional fee that would not have occurred if not for the DRM placed on the expansion packs? Another instance I have is that another friend of mine and my self both purchased the game "Command & Conquer: Red Alert 3" on the release date, my friend has a Laptop so he brought it with him so he could play the game on the way back to town, however when he went to install the game it would not let him as the game requires internet access to be authorized to play the game. (we pre-ordered this game at an Electronics Boutique Canada in the nearby city of Nanimo) All these protective measures I can understand, pirates are stealing games on a large scale. But if we take a look at recent games where DRM was applied heavily and in the most advanced ways currently possible such as EA's "Spore", the game was available for illegal download from the pirate's within a week of release *and that the illegal version even had more benefits than the official version such as being able to have more than one save file per purchased copy and also became the most pirated game of the year with over 1 million downloads within two months of the launch date. Why do we the paying consumers have to face the consequences for what the pirates are doing to the industry when the consequences we face are not even effecting the pirates in the least bit? *according to various news sites.
Comment Number: 539814-00180
Received: 1/8/2009 11:16:44 PM
Organization: N/a
Commenter: Patrick Henry
State: WA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is nothing but a bane on consumers, and no obstacle at all for pirates. If someone wants to buy the product, they'll get potentially harmful DRM programs on their computer which can amount to nothing less than malware. If it worked, it would be different. But it doesn't stop piracy. It just ruins people's computers. DRM should be stopped.
Comment Number: 539814-00181
Received: 1/8/2009 11:17:40 PM
Organization:
Commenter: Theresa-Kanae Cho
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

As both consumer and developer (I am an associate producer at a southern California studio), I am well aware of the need for protection of developer and publisher rights. However, as the war over DRM escalates, it has come to the point where excessive DRM infringes on the ability, the right of the consumer to enjoy that which he has paid for - while unscrupulous pirates simply crack the software and enjoy it at their leisure. More than once, consumers have publicly bemoaned the difficulties of enjoying games they have paid for in full - and turned to pirates for solutions. One need only Google infamous examples like SecuROM and Starforce - and recent AAA releases like Grand Theft Auto IV and Spore - to see just what kind of an impact draconian DRM measures have. There is need for DRM - the problem that needs solving at this point is how to architect it such that the consumers aren't the ones paying the price while pirates laugh it off. Gabe Newell commented that adding value - not punishing consumers - was the way to go. It's about incentive, not chains. And while this isn't a viable solution for some, it's a thought that merits strong consideration. How can we, as developers, convince our fans and customers to purchase our software, even when it's waiting out there on the internet (illegally) for free? That's what we need to figure out. As an example, Apple recently announced that it would be removing DRM from their iTunes store. This is a store where a consumer can purchase songs with convenience, and while the Internet makes it so easy to steal - the iTunes store pulls in millions because of the features and content it provides, because it is simple and easy and the services are worthwhile. I realize I have not provided a solution in this letter, and for that I am sorry, because I wish I had one. But I wish to close by stressing that we cannot continue to punish consumers who spend their hard-earned money to enjoy our game and support us, the developers. We cannot give them arbitrary install limits, we cannot install policing software like Starforce behind their backs, and even inconveniencing them to keep the purchased disc in their DVD tray (a tactic easily and invariably cracked by pirates - then downloaded even by those that purchase the game) is not accomplishing much, if anything. Thank you for your time.
Comment Number: 539814-00182
Received: 1/8/2009 11:18:54 PM
Organization: Certified Computer Consultants, LLC
Commenter: David Meacham
State: VA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I am an IT consultant and network engineer, and see first-hand the sorry state of DRM technology in several computers every week. The content owners hire a firm to come up with a program to ostensibly protect their content. The firm then, with no oversight or obligation to put out a safe or responsible product, kludges together something that they think will keep people from accessing the content. This solution is usually some kind of brute-force approach that will endeavor to replace the computer's inner workings to prevent whatever they don't want to happen. If, for example, they don't want the consumer to copy a CD, they overwrite the CD drive's drivers with their own software that explicitly disallows such copying. If this breaks the consumer's computer, what do they care? Most often the consumer has no way of knowing that the music or movie or program they purchased inflicted this damage on their system. All they know is that it suddenly began to act erratically or stopped working entirely. Meanwhile, the pirates and thieves of the world strip out the DRM program and receive the same content with no damage to their computers. Most programs for computers are available to pirates even before they hit the shelves on the store! The protection does nothing, at all, to deter or even slow the thieves. Meanwhile, the honest consumer suffers from the poorly-written DRM running rampant on their computer, without their consent (the consent having been buried in the middle of a twenty-page contract that flashed up when they installed the program). It's a cruel irony that DRM ensures that the honest person suffers while the dishonest person is completely unaffected.
Comment Number: 539814-00183
Received: 1/8/2009 11:19:08 PM
Organization: N/A
Commenter: Kevin G
State: FL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM is terrible, especially in its current form. At minimum, it prevents you from actually buying stuff(say in this case, a song). You just buy permission to use it how the company wants for as long as they feel like letting you. At it's worse, its intrusive and dangerous. Take securom and some of its predecessors for example(I.E. starforce). They force their way into the registry of your computer as deep as they can go, often without notifying you( EA is the worst culprit) and are not uninstalled even when the product is uninstalled. Often, they are incompatible with each other(even different versions of securom are incompatible). This can cause problems in the products, or maybe even the entire computer. And DRM doesn't work anyway. Why should people pay for something they don't truly own, when they can very easily get it for free and use it as they please. Just look at Spore, the most pirated game ever.
Comment Number: 539814-00184
Received: 1/8/2009 11:22:15 PM
Organization:
Commenter: Wagner
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I think we should kill DRM It just makes it harder for the people like me that pay for items. Hacker are going to kill all your DRM you ever put out. The code is made by man and will be hacked by man.
Comment Number: 539814-00185
Received: 1/8/2009 11:27:16 PM
Organization: NA
Commenter: Brandon Ganem
State: ME
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I feel as though DRM makes using a product harder. It something that can mess up your computer if implemented wrong, cause a hassle because you don't have an internet connection when you want to play the game and is just a down right annoyance. DRM in music is terrible too, buying a song in itunes means that i can only use the music on an ipod or burn it to a CD. That doesn't seem right to me and I feel that its limiting digital sales. As a paying consumer I as a rule avoid anything with DRM in it like the Plague. Thank you for reading this and For making this available.
Comment Number: 539814-00186
Received: 1/8/2009 11:29:24 PM
Organization:
Commenter: Padgett
State: LA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Many companies maintain that DRM is necessary for them to protect their copyright; however, I find this argument specious, for there have been few cases where it has significantly delayed the piracy of music, software, and other electronic goods, and no cases where it has outright prevented the piracy thereof. Considering that the Digital Millennium Copyright Act gives DRM the force of law, even when it prevents fair use, I think it is questionable if companies should be able to just use any sort of DRM they please. Still, I will concede that point for the time being for the sake of the issue at hand. It is absolutely crucial that every DRM-containing product explain its DRM and how it will affect one's computer clearly and in detail on its packaging. To not explain the DRM at all, which is a popular practice at the moment, is to undermine a user's control of their own computer, of their own property, and to not explain the DRM on the product's packaging, or to explain it only in a manner that is difficult to understand, is to force the consumer into a gamble on whether or not this product will contain something they don't want on their computer. Requiring DRM to be detailed on a product's packaging seems like a win-win situation to me; the companies can use DRM as they see fit and the consumer can know exactly what they are buying. The only reason I can see for anyone not to want a product's DRM detailed on its packaging is if a company wants to try to trick a consumer into buying a DRM-laden product that they would not want if they were fully informed of its nature, which is obviously a grossly unfair thing to do. Just as foodstuffs must have their nutritional information detailed on their packaging so that consumers can know what they are putting into their body, DRM-containing products should have their DRM detailed on their packaging so that consumers can know what they are putting onto their computer. In fact, it is quite possible that a standardized DRM label similar to the nutritional label found on food and drink could be created.
Comment Number: 539814-00187
Received: 1/8/2009 11:34:45 PM
Organization:
Commenter: Avery Krouse
State: GA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

It is my belief that the concept of Digital Rights Management is as worthless a method of controlling the proliferation of digital properties as speed limit signs are for controlling the maximum speed a person will travel in their vehicle. Essentially, if one wants to steal or pirate any given material, be it a music track, a video game, a movie, or any other digital product, one will find a way. In the meantime, technologies such as DRM that limit the way a paying customer can use the product he rightfully paid for posit little more than an encouragement to steal. If I pay 0.99 for a music track on Apple iTunes, it should be my prerogative where, when, and how I listen to that track. I made the decision to take the high road and pay my own money for a song I may listen to perhaps once or twice a month, why should a company control the method by which I do so? I would take any wager that states 100 of the 100 top selling tracks on iTunes are not available through illegal methods from any of a hundred avenues. However, those consumers that choose to pursue the avenues that are legal and upright are punished with restrictive regulation and electronic locks preventing us from enjoying that which we purchased.
Comment Number: 539814-00188
Received: 1/8/2009 11:39:38 PM
Organization:
Commenter: Shiro amada
State: FL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I Personally think that DRM punishes the legitimate customers more then the pirates. Games are usually cracked by these "scene" groups a few days to a weak after the game has been released giving these pirates a DRM free copy where as the loyal customers who actually purchased the game have to deal with headaches of annoying and possibly harmful 3rd party software, online activations and limited installs. If I pay for a game shouldn't I have the right to install it as many times as I want and not have to connect to the web to tell the company i want to play. Whats next, am I going to buy a dvd and be told I can only watch it X number of times and only on one dvd player after i call the company and get an activation number?
Comment Number: 539814-00189
Received: 1/8/2009 11:41:43 PM
Organization: none
Commenter: Jason Heffron
State: IL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

The use of DRM in games, software, and musice are just downright silly. personally I dont want anyone to install anything extra on my pc without giving me consent if at all. DRM is easy to get around if you are a pirate, so all that DRM does is hurt the legal consumer not the people that DRM is designed to fight.. DRM is a big joke. Personally I mainly make a point to stay away from any software or company that uses it. There are other non-invasive ways to check legitimate copies.
Comment Number: 539814-00190
Received: 1/8/2009 11:41:47 PM
Organization:
Commenter: Randy Edwards
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

The way I see it, typically, DRM enters the game market with CD protection technologies. What that basically is is algorithms that maintain a means of identifying the patterns of "special error bits" or otherwise needed data ON the cd medium. This is a strategy used to attempt to identify what IS or isn't a burned copy, since a bit-per-bit identical copy of a disk is a difficult thing to get. Unfortunately, the only way they can ever accomplish this is with special system drivers for the system (which slow it down, by design) Unfortunately, what I see is the inevitable problem of what this type of DRM is trying to accomplish. Basically, they're trying to stop someone who does not have the original cd from playing the game. While that propostion is a fair ideal, I URGE you to reconsider the what you're proposing. A cd is a blueprint. A game is a blueprint. But, like all blueprints, you can extract pieces of information that you need. For instance, if you had a blueprint for a ship, and you wanted it without an anchor (god forbid!), you would get all the data from the ship's blueprint, and leave out the anchor. CD protection is much the same. A CD IS a blueprint. It's an idea contained in a stateless form. Anyone looking to extract the information they're after can do so, given a sufficient education on software engineering and reverse engineering. What I see as the inevitable problem of CD protection, is that installing kernel drivers is INVASIVE. It's a resource hog, and unfortunately it DOESN'T stop the fundamental problem: Once you release a CD to the public, you've released a blueprint. Be it a complicated one (i.e. intensive reverse engineering to find where the anchor is), or a simple one (i.e. no difficult in locating the anchor in the software). And since you've released a blueprint, you've given them a complete copy of the software, regardless of whatever CD protection mechanisms you install on the CD, or introduce without public concent into windows. What I'm saying is, it doesn't solve anything. It's an idea founded n the expectation that those who go against the software liscence are not smart enough to read the blueprint FOR the blueprint (contained on the CD), and it installs unnecessary software on everyone's machines that hinders performance and gameplay. To paraphrase what they're trying to accomplish, imagine selling a blueprint of a ship, that has it inscribed "you can't remove the anchor from this blueprint", and it so happened that the anchor was taking resources from shipbuilders funds. Now give that blueprint to a 5th grader. and hand him some whiteout for the anchor. Hopefully now, you will realize how much of a waste CD protection is. It doesn't stop the problem.
Comment Number: 539814-00191
Received: 1/8/2009 11:43:19 PM
Organization:
Commenter: Phil Thorn
State: VA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I understand the desire for artists and other producers to prevent piracy of their works, but I believe DRM only aggravates the situation. As best evidenced by the game Spore, DRM is in no way foolproof and only served to condemn the game and developing company in hundreds of thousands of gamers' eyes. As countless others have stated, with the DRM that Spore and other games had, what you got was more or less a rental of that game. ITunes made a smart move in removing DRM from its songs, and such a practice is followed by others consumers and publishers alike will benefit.
Comment Number: 539814-00192
Received: 1/8/2009 11:43:52 PM
Organization:
Commenter: Jon McCarty
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I think the FTC and any government organizations need to take a very careful look at the role DRM truly plays in the world of digital media and whether it has a net positive or negative effect on consumers, businesses and the economy. While the ideal behind DRM is noble, the execution and the vigor with which it is handled goes far beyond what should be considered reasonable. My personal experiences have been quite off-putting. I work as a software developer and have on multiple occasions found myself unable to properly use a purchased piece of software because the DRM protection prevented the program from running if I had previously loaded a 'blacklisted' program from another company. This blacklisted program is a commonly used system analysis tool distributed by none other than Microsoft themselves, and to top things off the blacklisted application was not even running at the same time as the DRM protected application. The DRM protected application simply detected that it had been run earlier in the same session. One then has to restart their computer in order to use the DRM protected application. Given the amount of work I do on a computer, these problems tend to compound the more I use application protected by such draconian DRM schemes. While the example cited above may seem a bit outside of the realm of the common user's experience, there are countless similar examples I hear every day. Friends and family complaining about being unable to use media devices because their TV isn't new enough to support HDCP, kids unable to use purchased music because the music can no longer phone home due the the music stores going out of business (this could arguably be attributed partly to the absurd DRM scheme), soldiers overseas unable to play video games during their free time due to more phone home schemes, and let us not forget Sony BMG's installation of dangerous rootkit software prior to license agreement from users, and without any method of removal. This last blunder not only caused errors including system crashes on users' machines, but opened serious security holes. I think these companies have shown a complete disregard for their customer base and the public at large, and have made it very obvious that they are willing to overstep reasonable bounds in order to protect their revenue streams. What these companies seem to either miss, ignore or simply not care about is that they are alienating the public and damaging their own holdings and the economy at large. There is rarely a day that goes by where I do not read reading about another absurd 'copy protection' mechanism causing users grief, and from what I have seen this has done nothing to stem the tide of piracy. It is all too obvious that you can get any piece of digital media the day it is released, if not earlier, without regard for DRM. This all begs the ultimate question of who DRM really hurts? I hope it is a question that the FTC will keep in mind.
Comment Number: 539814-00193
Received: 1/9/2009 12:10:54 AM
Organization: Control Shift
Commenter: Daniel Russell
State: TX
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Digital Rights Management Software quite literally causes problems with computer use at a base level. I work in the Technical Support business, and I do get frequent requests on how to bypass DRM technology constantly. People purchase software, and expect to have the freedom to use it, and what's more think they have unalienable, government protected freedoms with their software because they paid money for it. I explain in base terms that people do not have these rights because they have been traded away for money, and they get very upset constantly. They tell me things like I hate computers and Why did I buy this anyway, I don't think I'll make further purchases from Microsoft, or other companies that use this type of garbage. In my business life I believe DRM needs to be considered a form of malware that obstructs users from getting full use of their software. This headache of DRM amongst my generation (I'm 27 years old) has put a hamstring in the way we do business, how I need to solve problems, and more over causes a negative consumer impact on products to be purchased and used. It was a bad idea in the first place made by overly greedy software creators, and now is simply a relic that can be easily bypassed by thieves, pirates, and other criminals. People would not pirate software if the software was 1) reasonably priced 2) easily copied and 3) easily made to be reinstalled upon computer failure. This country's failure to protect the people's rights regarding software has been huge, and the backlash from illegal piracy rackets powered by law abiding citizens has been grandiose. Ignoring this problem, and stating DRM is a necessary evil is to give software users everywhere around the world little hope to access a wealth of information. Countless times it has been proven that DRM free software makes for GREAT software. As examples I look at Mozilla Firefox, Ubuntu Linux, OpenOffice, a lot of software developed by Apple Inc for use on Apple Computers, and much of the GPL Licensed software. Check the Creative Commons, Free Software Foundation, and Larry Lessig for more data. If you want to know what DRM Free software helped make; check the iPhone's Web Browser - it is based on WebKit - an Open Source and totally DRM free Web Browser. While the iPhone itself does have some DRM restrictions, it does go to show perhaps the BEST part of this device came from Open Source effort with no DRM restrictions on who uses it, or builds upon it.
Comment Number: 539814-00194
Received: 1/9/2009 12:11:28 AM
Organization:
Commenter: Jason Cunningham
State: WA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Thank you for addressing this issue. I'm a firefighter by trade and have little skill or knowledge of computers. Putting DRM software on the things I buy is overkill at best and insulting/irritating at worst. If the idea of DRM is to prevent widespread copying and illegal selling then it's unnecessary for guys like me and ineffective against the real hackers out there. If somebody sells a quality product I will pay for it. I've already paid for freeware that I liked (crap cleaner). Get rid of DRM, please.
Comment Number: 539814-00195
Received: 1/9/2009 12:11:52 AM
Organization:
Commenter: J. Doles
State: LA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

1. I despise most forms of DRM. Inconveniencing legitimate customers does not make piracy less attractive. 2. Please do not create a set of DRM Rules & Regulations. This is a consumer matter that can be solved by more aware, more experienced consumers. Example experiences include: *Discovering your .wma music files no longer play, because an activation server has been taken offline. *Discovering that your software will not run because it has detected "pirate tools" such as debugging or CD emulation software on your system. *Being called a pirate and a criminal when contacting tech support about a DRM-related problem. *Ignoring the "Internet Connection Required For Play" small print when purchasing a game because you are not interesting in multiplayer online play. (on a side note, America's broadband penetration leaves much to be desired). *Purchasing DRM-laden songs from a company that later announces that they will now sell the songs DRM-free, but you have to pay %30 of the purchase price to upgrade your songs.
Comment Number: 539814-00196
Received: 1/9/2009 12:18:05 AM
Organization:
Commenter: Jerry parker
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Dear FTC. I will never buy DRM protected music ever again! No purchase, then no Trade, and no reason for FTC. I have 22,000 songs on my itunes playlist, and I have never, ever illegaly downloaded a single one. I am quite happy to pay a fair price for them, but once I own them, I do not expect Apple or anyone else to control my access to them. DRM does not prevent bad people from pirating, it only affects people who actually paid for the product
Comment Number: 539814-00197
Received: 1/9/2009 12:18:45 AM
Organization: n/a
Commenter: Waringa
State: CO
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

As an American consumer I feel that I have a stake in these proceedings, and am therefore and interested party in this discussion. Currently I work in a technology related field and feel that I can offer an interesting perspective on the topic of DRM. For years now I have been both the victim and savior (to friends and family) of DRM related problems. In all of its iterations and forms DRM is far from a perfect technology. For years the consumer has slowly become an unwilling participant in lab rat trials to perfect the holy grail of "copy and distribution protection". Every new version of DRM brings a new set of problems that are forced on the consumer. The "consumer" (my grandmother) does not care how the technology works to get her mp3 or piece of software from point A to point B for use. She merely cares that it works and more often than not.... it doesn't. If a seat belt/head lamp/fuse in a car doesn't work as intended is there not a recall? Do we not as a nation hold other industries accountable for delivering on the products they sell? Why has the technology/music industry been allowed for SOOOOOO long to skate by with excuses like "The consumer just doesn't understand the product" or "We will get it right in version X of the software"? If you read nothing else in my comment to this work group, I urge you read this:-----------------Any DRM can be easily circumvented or broken given little effort via analog recording. The industry knows this but ignores it and continues to fight a useless but profitable battle. This battle is a FRONT for the ability to trouble the common consumer and force them to pay for multiple copies of the same product. The average consumer does not have the knowledge required to troubleshoot legitimate file copies that inevitably will fail and cause NUMEROUS problems resulting from DRM protection. The industry knows this and preys on the consumer for increased sales of the EXACT SAME MEDIA. If the FTC would like evidence of this look no further than Apple charging higher prices for non-DRM media. Is the Non-DRM content of which they are selling any different from the DRM content they sell? NO! Is the price the same? NO! They are ripping off the consumer and making money of an industry created copy protection mechanism!!!!--------------DRM is a fraud and a theft to Americans that the FTC needs to stop.
Comment Number: 539814-00198
Received: 1/9/2009 12:19:27 AM
Organization:
Commenter: Michael Buffaloe
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

Before I begin my comments, allow me to quote Gabe Newell, co-founder of game development company Valve Corporation: "As far as DRM goes, most DRM strategies are just dumb. The goal should be to create greater value for customers through service value (make it easy for me to play my games whenever and wherever I want to), not by decreasing the value of a product (maybe I'll be able to play my game and maybe I won't). We really really discourage other developers and publishes from using the broken DRM offerings, and in general there is a groundswell to abandon those approaches." DRM, plain and simply, does not achieve it's purpose. Video game piracy is not hindered by DRM in any recognizable way, as DRM may only delay a pirated "release" up to 5 days after it would have been available without said DRM. DRM does, however, severely hinder what customers are allowed to do with the content they purchased. A customer should be able to do whatever they like (within legal and copyright limits) with the video game software they own, including copy it onto multiple PCs and reinstall without a required internet connection for verification. DRM does nothing but hinder the gaming community, and it should be either severely limited in it's usage or removed completely from the table. The latter is preferred for most gamers.
Comment Number: 539814-00199
Received: 1/9/2009 12:21:41 AM
Organization: Student at Vermont Technical College
Commenter: Sean Burke
State: VT
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I am a proud member of the gaming community. I am currently enrolled in Vermont Technical College for Computer Engineering Technology. I feel that DRM should no longer be allowed to exist within video games. Over the past few years I have noticed a rapid increase in the level of DRM found in computer games. I know that I am not alone as gamers all over the internet have expressed their outrage for excessive DRM found in today's video games. The DRM is meant to block those who intend to play an illegal copy of the game, but it should not, in any way, work against a user's experience who is playing the game legally. Recently games have gotten away with excessive DRM. This has included being able to install a product only a certain number of times before it will not legally work, requiring online activation and/or an online account in order to play, and even 'chopping' down the user's experience if the game suspects that it isn't a legal copy. DRM is meant to stop hackers from downloading and sharing illegal media, but this level of protection should never be able to affect a user's experience. I feel that DRM has the right idea, but it is using the wrong method. DRM has proven to be much more of an annoyance to those who legally own a product than it is to those who chose to illegally reverse-engineer the product, and then share it over the internet. DRM has proven to only succeed in negatively affecting a legal user's experience for the sake of stopping the tiniest percentage of individuals who choose to illegally exploit a commercial product. DRM has even gotten to the point where it installs Spyware applications on a user's computer to verify the legality of certain products. We as consumers should not have to suffer the consequences of the hacker minority. I believe that companies should no longer legally be allowed to place DRM software within their products that limits a user in any way, shape, or form. I ask the people of the Federal Trade Commission to seriously consider banning companies from using DRM as a means of copy protection. DRM is not the solution, but instead it has become a problem. Thank you for taking the time to read this. I am sure that I speak for the majority of gamers in saying that DRM should no longer legally be allowed to exist on a products that we, the consumers, have legally purchased. Please consider the gamers with the action you take to change DRM.
Comment Number: 539814-00200
Received: 1/9/2009 12:23:08 AM
Organization:
Commenter: Jose Santiago
State: FL
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I feel that if I purchase something, I should be able to use it how I feel. If companies feel that they need to control how we use these items than they should be in business!
Comment Number: 539814-00201
Received: 1/9/2009 12:23:30 AM
Organization: N/A
Commenter: Ashby Herman
State: VA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

DRM creates a horrible customer experience as far as I am concerned. I'm sure others who stick with one company blindly forever may never even know, but if I pay cash to own something... I should own it with no stipulations which may make me using a different computer, player, format, difficult thus forcing me to repurchase the product again.
Comment Number: 539814-00202
Received: 1/9/2009 12:25:19 AM
Organization:
Commenter: Robert McAdams
State: CA
Agency: Federal Trade Commission
Rule: FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:
Comments:

I abhor the more aggressive forms of Digital Rights Management (DRM) in use today. I am specifically NOT buying new games from Electronic Arts (EA) right now, because of the draconian DRM they include in their games. EA is the worst about DRM these days. My basic stance on DRM, is that it should not interfere with the legitimate buyer's enjoyment or use of the product which they have bought and paid for. I, the buyer of the product, should be able to install it on my computer as many times as I want. If it is music, I should be able to play it on whatever device I want, share it with my friends (just like I could with CDs, and cassettes), etc, and resell it when and if I am done with it (just like I was able to do with CD and cassette). If it is a video, I should be able to view it on any device I own, without a loss of digital quality, or any insane hoops to jump through, and without being treated like a criminal. The people they should treat like criminals, are the ACTUAL criminals pirating their products and/or making money off of their intellectual property -- that is what the legal system is in place for. My involvement with the company selling the product should END once they have my MONEY! I do not object to serial numbers to unlock the content. I do not object to most of the various forms of DRM invented and thought up before 1998 or so. Since then, however, companies have dreamed up forms of DRM forcing me to have an internet connection to use their product, forcing me to call them and get new serial numbers/keys when I have installed their product on my computer more times than they think I should. They also have managed to install ROOT KITS on my computer along with the music I bought from them. And there are now versions of the DRM which make it almost impossible to remove from your computer, even if you only download the DEMO of the software. This is unacceptable. The real insult to these injuries is that most if not all of these modern DRM tactics are not DISCLOSED to the consumer in plain English on the packaging, BEFORE the consumer buys the product. Instead, it is buried in an EULA hundreds of paragraphs long, in legal jargon. These tactics have resulted in consumer boycotts and, ironically, massive pirating of various software (as reported on the news in many outlets) as a form of protest. I urge all companies employing these draconian DRM schemes to knock it off, before they drive THEMSELVES out of business.