Omissions in CDT's DRM report

The Center for Democracy in Technology has released a report on DRM and consumer rights, intended to serve as a guideline for governments who are looking to balance consumer interests with legal protection for DRM, which is technology used to limit how we can use the media we buy on the devices we own.

This is a good goal, but the paper falls far of the mark, by omitting any mention of DRM 'renewability" (the ability of a DRM vendor to take away rights you got when you bought your media or device), open source (which is antithetical to DRM), and Creative Commons (which can't be used in connection with DRM.

I've written an open letter to the CDT staffers listed as contacts on the paper, going into detail on these subjects:

All new DRMs are being designed to be "renewable." The Sony PSP
was repeatedly patched to force users to stop running their own
software on their devices. BluRay and HD-DVD are both built
around a "renewability" system that can shut down devices. The
Broadcast Flag ruling provided for renewability to disable
consumers' property on the grounds that if someone, somewhere
figured out how to use a DVD burner to circumvent the flag, all
innocent users of that burner should be punished to get at the
guilty. This week, Microsoft issued its fastest-ever OS patch to
remove a DRM crack that users applied in order to make lawful
uses of the content they owned.

What kind of disclosure is sufficient here? What constitutes
transparency? "This device will do the follow five things and
restrict your from the following eight things. However, at any
time in the future, without your consent, a secret commercial
body with closed membership and meetings may shut down any of
this device's features, with no appeal."

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