I agree that this specific provision doesn't as directly affect people uploading to Wikimedia Commons.  But I worry that the US Copyright Office will only be hearing from people who do searches in an industry context--people who have access through their companies to all sorts of databases and the money to hire researches for searching, and assume that any reasonable search would involve that sort of time and expense and specialized knowledge, rather than what a reasonably diligent, good-faith person working on their own time could do.  

I figured that they could stand to hear from the experiences of people who do other sorts of searching and noncommercial uses, so they can get a sense of what sorts of barriers noncommercial users face.

The standards that they use here could easily be adopted for other uses later--"reasonable search" was a big sticking point in broader orphan works legislation proposals in the past, for instance.

So it's not about direct effects on Wikimedia Commons so much as laying groundwork for them to understand the breadth and capabilities of volunteer, noncommercial uses.

Best regards,

Sherwin

From: R. Acconish via Commons-l <commons-l@lists.wikimedia.org>
Date: Thu, Nov 29, 2018, 9:32 AM
Subject: Re: [Commons-l] Commons-l Digest, Vol 160, Issue 6
To: <commons-l@lists.wikimedia.org>