1. The $500.00 minimum annual payment to SoundExchange, for 159,140 ATH per month performances, or a bulk minimum buy of 22,916,160 digital music performances of statutory music, is very much greater than the actual use of the statutory license by small noncommercial webcasters, like IBS Members.

IBS Members, noncommercial webcasters, are overwhelmingly entities of the 50 States,
like public schools, community colleges, colleges, and State universities.

Therefore excess, unjustified royalty fees, are excess TAXES!

The CRB - Copyright Royalty Board forced minimum bulk purchases for the use of the statutory digital music streaming license, webcasting, covering roughly 218 continuous listeners 24 hours a day, 365 days a year.

The reality is that virtually all new high school and college webcasters operated by public education entities do not exceed four (4) continuous webcast listeners (4 is 2% of 218).

Many of these listeners are not listening statutory digital music performances, but instead are listening to sports, talk radio, and other non-statutory digital music.

For eight (8) continuous listeners, roughly 4% of the 218 listeners included in the minimum $500.00 license fee the actual use of the license is about $20.00 worth per year. (4% of $500 equals $20). IBS describes this proposed rate as the webcast performance copyright annual fee for very small noncommercial webcasters.

The above proposed IBS webcast annual webcast royalty rates for use of the statutory digital music license for which SoundExchange is the sole collective are: $20.00 annually for very small noncommercial webcasters.

IBS has offered SoundExchange (SX) to pay SoundExchange $10,000.00 annually to cover the royalty fee for up to 500 IBS Members ($20 each) as an aggregator for IBS Members. A single IBS check and IBS assistance in administration for SoundExchange would greatly reduce SX costs, which are deducted from label/artist revenues SX pays out.

2. PUBLIC Education entities may be prohibited from using the Internet/Webcasting to teach America's Sons and Daughters about digital communications by the $500.00 minimum rate, a hugh minimum bulk purchase of 22,916,160 performances annually. Students should be allowed to learn/practice vital digital communication/Internet SKILL Sets required by them to survive in the Global World Economy!

3. The Corporation for Public Broadcasting (CPB) receives annually from US Taxpayers, by Congressional Authorization/Appropriation over $400,000,000.00 ($400 Million Dollars). CPB pays, using Federal Taxpayer dollars the SoundExchange copyright royalty fees for all NPR and CPB Qualified, webcasters. State and local taxpayers often must pay SoundExchange webcast royalty fees. Federally funded high visibility mass audience (over 200 continuous listeners) are given preferential rates. State and Local Government funded training entities often with very low listenership (20, or even 5 or less listeners per minute), due to the minimum must pay the $500.00 minimum rate even though their pay per performance rate is less. Often the use of the statutory music license is only 4% of the federal funded NPR webcasts.