The Big Comment Catalog Project:

What Did the Public Say About DeVos's Proposed Changes to Title IX?

UPDATE on cataloging progress: We are still cataloging, so there is still time to volunteer! Click on the "How Can I Help?" link below for more details on the progress we have made since this project launched.


Welcome to The Big Comment Catalog Project! This is a "crowd-researched" project to catalog each of the comments filed in response to the Notice of Proposed Rulemaking issued by Secretary of Education Betsy DeVos in November 2018 regarding Title IX and sexual harassment ("Title IX NPRM").

Over 124,000 comments were filed in response to the Title IX NPRM. Members of the public filed this historically large number of comments despite Secretary DeVos's decision to allow commenting for only 60 days, scheduled at a time of year when many students were engrossed in studying for and taking exams and then most schools were closed for their regularly-scheduled winter breaks. In addition to this comment-filing discouragement-by-design, the public faced additional obstacles to filing comments when the federal government shutdown took up 35 of the 60 days in the comment period, and prevented quick troubleshooting of several malfunctions of the commenting website.

Especially in light of these impediments to commenting, the contributions of those who did comment should be recognized--by ensuring that their comments can be read and engaged with, not only by Betsy DeVos' Department of Education ("ED"), but also by other members of the public who are interested. Unfortunately, however, although the comment process as defined by the Administrative Procedures Act requires ED to both read and seriously consider all comments, the law does not require ED to make available to the public whatever catalog of the comments ED may create in its internal comment-review process.

The Big Comment Catalog Project is designed to fill this gap by creating a database about the comments that will make it easier for all members of the public to read, report on, and otherwise use the comments filed in the Title IX NPRM. As a crowd-research project, volunteers are needed to read and collect data from the comments. We hope you will volunteer!

How Can I Help?

If you would like to participate in this project, please click the "I want to adopt 20 comments" button (below) to sign up for a batch of comments, then follow the instructions (below and on the form) to catalog each comment in your batch. No specialized knowledge or skills are required. We suggest signing up for 20 comments as a start and signing up for more once you know how long the first 20 took you to catalog. PLEASE NOTE (Trigger Warning): Comments may include information that is triggering to individuals who have been involved in instances of sexual harassment, gender-based violence or other traumatizing conduct. Please make your decision to volunteer to read and catalog comments with this warning in mind.

The crowd-researched aspects of this project are being coordinated by some of the members of the research team that read and analyzed the 16,000+ comments discussed in the Widely Welcomed and Supported by the Public report. If you do not have time or have other reasons why you cannot catalog comments but may like to contribute in other ways to this effort, please contact the research team at

Without a model on which to base a timeline for this research, we did not meet our initial goal for completion of the catalog (July 8, 2019), but we are hopeful that this research can be completed by the end of the summer. Our volunteers have been cataloging an average of roughly 50 comments each.

We are so grateful to all who have already volunteered, and we hope you will be inspired to join them. Feel free to recruit your friends and colleagues to support this effort as well!

The Buttons: Adopt a batch, catalog each comment, tell us when you're done

How to Catalog a Comment

So, you submitted the form to adopt a batch of comments, and we've emailed your list to you. Here's how you catalog your comments--it's easy:

All you need is the internet, a computer, and a gmail email address (here's where to create a gmail account for free). In your email from us, open your list of 20 comments, and open the "Catalog a Comment" form.

  • Copy the first comment's URL from your list of comments.
  • Paste it into two places:
    • A new tab on your browser; and
    • The form's "Comment ID" field.
  • Referring to the comment, answer the remaining fields of General Information.
    • If the comment has attachment(s), open and refer to them, too.
  • Click "Next"
    • If the comment was about Title IX, continue answering the fields of Detailed Information. Then answer the fields on the Topics screen. (See the FAQs section below for the questions on these screens.) Then, click "Submit."
    • If the comment was not about Title IX, there's nothing else to log about it. Click "Submit."
  • Click "Submit another response" and log your next comment. (Hint: If you opened any attachments, close the first attachment(s) before you open the next comment's attachments.)
  • When you've cataloged all the comments in your batch, come back here and click the "I'm done with my comments!" button so we can thank you.
    • If you want another batch, check the box "Send me another batch, please" or come back to this page and click the "Adopt 20 Comment" button and we'll send you another batch.

Frequently Asked Questions

What if I can't remember if I already logged a question?

  • Just go ahead and log it again. We'll use the response with the later date.

I submitted a form to adopt a batch of comments and haven't heard back. What happened?

  • It may take us up to 2 days to send you a batch of comments. If it has been more than 2 days, please email us (below), so we can make sure the form is behaving.

What substantive questions will the “Catalog a comment” form ask after the first screen of general information?

  • Here are the questions:

Was this comment made on postcard(s)?

How long is the comment (not counting any attachments)?

In your opinion, was this comment written in favor of ("for") the Trump administration's proposed changes, or in opposition to ("against") those proposed changes?

Does this comment include a personal story?

In your opinion, does this comment, including any attachments, cite or discuss any research studies?

In your opinion, does this comment, including any attachments, include legal analysis or legal arguments?

In your opinion, does this comment discuss any of these topics? Please check all that apply. If you wish, you may use your browser's "find" tool to search for terms in quotations.

    • Definitions of “sexual harassment,” “prompt,” “notice,” “actual notice,” and/or "deliberate indifference"
    • Use of live hearings, mediation, and/or cross-examination
    • Off-campus or online sexual harassment, violence and/or misconduct
    • School provision of “supportive measures,” “protective measures,” “interim measures” and/or “accommodations” to students involved in sexual harassment, violence and/or misconduct
    • K-12 sexual harassment, violence and/or misconduct
    • Religious exemptions
    • Standards of evidence (“preponderance of the evidence” or “clear and convincing evidence”) and/or rights to appeal
    • None of the above

Other notes (optional) (For example: "this comment is written in a language I don't read," or "the attachments are illegible.")

More Questions?

The Research Team

  • Nancy Chi Cantalupo, Associate Professor of Law, Barry University Dwayne O. Andreas School of Law (SSRN)
  • Kenneth R. Bundy, Lecturer in Mathematics and Statistics, University of Maine at Augusta (webscraping/data collection)
  • Julianna Burchett, JD candidate, Barry University Dwayne O. Andreas School of Law
  • Mariko Cool (data manager, webmaster)
  • Brooke Mascagni, PhD, Victim/Survivor Advocate and Scholar (website, LinkedIn)