Bartow makes an excellent point when she discusses how the Digital Millennium Copyright Act (DMCA) creates a specific barrier to fair use access in relation to digital works.58 She points out that the DMCA “makes it illegal to manufacture or distribute devices designed to bypass technology that protects copyrighted material.”59 Making a back-up copy of a digital work, a practice that would be allowable with ink-and-paper materials would run afoul of the DMCA.60 Making allowable, under the Copyright Act, back-up digital copies violates the DMCA because it would require breaking through copy-protections.61 Subsection 108(c) of the Copyright Act allows libraries and archives to make up to three copies of a published work to replace those damaged, deteriorating, lost, stolen or obsolete in format.62 These replacement copies legally made under the subsection, however, cannot be made available to the public outside the library if they are made in a digital format.63 The limitation of access to only the premises of the library for digital format replacement copies does not extend to ink and paper replacement copies. When Congress amended subsection 108(c) with the DMCA it did so with the awareness of the