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From the US Copyright Office:
What is copyright infringement?
As a general matter, copyright infringement occurs when a copyrighted work is reproduced, distributed, performed, publicly displayed, or made into a derivative work without the permission of the copyright owner.
I do believe COPYING would be considered reproduction and providing said copies would be distributing.
Feel free to argue with the agency of the Federal gov't about their definition of what they do. Somehow, I won't be surprised.
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