Here's what I intend to submit. Any comments from the membership before I do?
Comment on Exemption to Prohibition on Circumvention of Copyright Protection Systems for Access Control Technologies
To Whom It May Concern,
The rules should state clearly that circumvention is not prohibited when it is done for non-copyright-infringing use. If it must be prohibited at all, then it must only be prohibited if that circumvention directly results in or was clearly intended to result in a copyright violation.
It should be made clear that circumvention is allowed in order to exercise fair use of the material.
As a specific example, the rules should make clear that circumventing DRM on ebooks and sound recording is permitted for the purpose or exercising permitted rights, such as personally reading or listening to the material, in a format or on a device of the user's choosing. Copyright law should not be used to force consumers to use one manufacturer's equipment over another.