a novel concept called Controlled Digital Lending (CDL).CDL, developed as a legal theory a bit more than a decade ago by the Georgetown University professor and law librarian Michelle Wu, asserts that libraries have a right to create digital surrogates for their collections, enabling each library to loan out either the digital version or the hard copy of any material it owns (but not both at the same time).

Controlled digital lending is a system that enables a library to circulate a digitized title in place of a physical one in a controlled manner.

We write on behalf of plaintiffs Hachette Book Group, Inc., HarperCollins PublishersLLC, John Wiley & Sons, Inc. and Penguin Random House LLC (the “Plaintiffs”) to request apre-motion summary judgment conference pursuant to Individual Practice 2(B).

I write on behalf of Defendant Internet Archive pursuant to Paragraph 2-B of Your Honor’s IndividualPractices to request a pre-motion conference on a motion for summary judgment in the above matter.