Well, the Registrar has spoken: "No exemption for you!"
Oh well. As I read it, it comes down to this:
If we want this matter made clear by the next rule-making cycle, we'll need:
1. New laws. Write your congressman. (A really
good law would obviate the need for an exemption.)
2. Cases that come to court and are decided in our favor, so there is a precedent for the Registrar to base an exemption on.
3. A lawyer to make a compelling legal argument on our behalf.
'Cuz, while it was indeed nice to see that our individual comments were being considered, the Registrar said they were just our stated opinions, not a legal analysis, and no proof that the uses we're discussing were indeed non-infringing or fair use. Note that they didn't say they WEREN'T, just that we didn't prove they WERE.