Commentary on the DMCA Rulemaking process by New Media Rights:
All of this effort is required despite Copyright owners offering specious or no evidence about any harm that’s being protected by not providing exemptions. Yes, you read correctly. Advocates are spending thousands of hours asking the Copyright Office to please make exemptions for a universe of uses that are, but for the DMCA Anti-circumvention provisions, in no way illegal! As one commentator put it, the narrow exemptions are “like a manicured garden in the middle a Superfund site.”