Analysis of answers to IPRED consultation

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This page aims at analysing the answers sent to the European Commission regarding the upcoming revision of the "Intellectual Property Rights" Enforcement Directive (IPRED)

Last Winter, the European Commission organized a large consultation on the future of IPRED, which is the main EU instrument in the war against the online sharing of culture. If the EU Parliament fails to reject the Anti-Counterfeiting Trade Agreement (ACTA) in its upcoming consent vote, the revision of IPRED will be the perfect vehicle to transpose in EU law the dangerous censorship schemes pushed by ACTA's digital chapter (visit http://lqdn.fr/en/acta to join the campaign against ACTA).

All sorts of stakeholders - be they Member States, businesses federations, corporations, lobbies, non-governmental organizations - have sent answers to the consultation (you can read La Quadrature's answer here). These submissions are listed below.

How to Help: Everybody interested in helping out can start reading a submission and identify each stakeholder's position regarding the war on sharing of cultural works online. What do they think of the EU Commission's plans to step up copyright enforcement by turning Web service providers (such as search engines hosting services) as well as telecom operators into a private copyright police?

What to look for: To quickly analyse the submissions, you should be looking for three key issues: What does a given stakeholder think about:

  • Liability of Internet service providers. According to existing law, Internet service providers (ISPs) are not legally responsible for the activity carried on by their users (thanks to the 2000 e-Commerce directive). These liability exemptions ensure that ISPs do not monitor their users' activity or restrict their freedom of communication. The Commission's consultation shows that it wants to bypass these liability exemptions, and enroll these actors to police their networks and services at the expense of their users' fundamental rights. Does the stakeholder show support to the liability exemptions, or does it call on ISPs to take a more proactive role in the war on sharing?
  • Cooperation between ISPs and copyright-holders. A growing number of policy-making efforts make references to "cooperation", "self-regulation" or "voluntary agreement", so as to turn Internet intermediaries into the gatekeepers of online communications in the war on sharing. Does the submission include such references"?
  • Measures to address copyright infringement, such as filtering. According to the Commission: "Internet platforms such as online market places or search engines can also play an important role in reducing the number of the infringements, in particular through *preventive measures* and ‘notice and take-down’ policies". Clearly, the Commission would also like to generalize wide-filtering schemes. Does the stakeholder criticize such dangerous scheme, or does it endorse them?

Tips: Copy-paste key excerpts of the submissions in relevant sections. Please provide a short sentence in english if the quoted text is unclear or in antother language.

Sommaire

Analysis of submissions to IPRED consultation

Public authorities

Ak Oesterreich (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Belgium (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Bulgaria (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Czech Republic (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Danish Chamber Of Commerce (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Denmark (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Deutscher Bundestag (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



European Parliament Committee On Legal Affairs (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Finland Ministry Of Empl And Economy (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Finnish Commerce Federation (fi)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



France

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Germany (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Hadopi (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Hungary Ministry Public administration And Justice (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ireland (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Italy Ministry Of Agrifood (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Italy Office Of The Prime Minister (it)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Latvia (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Lithuania Ministry Culture (lt)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Malta (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Netherlands Ministry Security Justice (nl)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Parti Pirate (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Poland Ministry Culture (en, pl)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Portugal (pt)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Romania (en, ro)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Slovakia (sk)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Spain Ministry Of Justice (es)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Uk Governement

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Wko Austria (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*

Organisations

Act (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Aepoc (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Afep (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Aim (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Aippi Belgium (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Aippi Finland (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Aippi General Secretariat (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Allegroup (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Alliance Against Ip Theft (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Alstom (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Andema (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Anica Fapav Univideo (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Apm (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Apram (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



April (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Apt (it)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Association Francaise Ubuntu (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Assotelecomunicazioni Asstel (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Aukro Bulgaria (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Aukro Czech Rep (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Aukro Slovakia (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Bascap (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Bdwi (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Bdzv Vdz En (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Benelux Verenging Voor Merken En Modellenrecht (nl)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Beuc (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Bits Of Freedom (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Boev (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Bouygues (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Brein (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Bsa (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Bskyb (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Businesseurope (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Bwin Party (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Cable Europe (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Cable Europe Ecta Etno Euroispa Gsma (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ccia (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ccip (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ccip Fiche Synthese (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Cefic (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ceipi (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Cepi Fera Fiad Fiapf Ivf (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Chartered Institute Of Pa (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Cmba (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Cnac (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Colipa (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Comite Colbert (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Confindustria (it)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Confindustria Servizi Innovativi E Tecnologici (it)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Constant (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Consumer Focus (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Dacs (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Danish Copyright Council (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Danish Patent Agents Association (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Danske Universiteter (dk)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Dbf (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Deutsche Patentanwaltskammer (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Deutsche Patentanwaltskammer Cover (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Deutsche Post Dhl (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Deutsche Telekom (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Deutscher Anwaltverein (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Deutscher Markenverband (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Dihk (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Eaea (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ebay (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ebca (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ebf Contribution (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Eccia (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ecta (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Edima (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Edps (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Edri (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Efpia (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Egdf (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Egeda (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Egma (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Eli Lilly (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Emeca (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Enpa50 (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Epa (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ericsson (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Esa (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Etno (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Eurocopya (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Euroispa (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



European Fashion Council (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



European Producers Club (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



European Publishers Council (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Faep (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Fast

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Fastweb (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Fdn (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Fep (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Fesi (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ffii (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Fimi (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Fondation Giacometti (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Fondation Hartung-bergman (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Fondation Le Corbusier (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Fox International Channels (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Fsfe (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Gema (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Gesac (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Gi Dpi (es)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Giart (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Gleiss Lutz (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Google (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Grupa Allegro (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Grur (de, en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Gsma europe (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Hai Europe (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Icc (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Icmp (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ifpi (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ifrro (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Indicam (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Inta (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Intel (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Internet Society (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Internet Society Poland Panoptykon (pl)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ip Federation (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ipo (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Isfe (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ispa Austria (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ispa Belgium (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Iuridicum Remedium (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Johan Schl�ter Advokatfirma (dk, en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Kepka (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Kopiosto (fi)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ksb Sas (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



La Quadrature Du Net (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



La-ex Fcforum (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Les (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Lesi (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Lyhty (fi)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Marques (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Medef (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Mediaset (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Microsoft (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Mih (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Mpa (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Nuovo Imaie (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Nurpa (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Org (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Philips (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Pike (pl)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Pin Sme (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Pirelli (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ppl Uk (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Publishers Association (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Qdlaty (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Qxl Ricardo Denmark (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Qxl Ricardo Greece (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Rga (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Rim (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Royal Tnt Post (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Royal Tnt Post Taxud (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Saa (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Sabam Form figures (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Sabam Questionnaire (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Sacd (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Sacg (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Sazas (si)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Sek (fi)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Sroc (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Stm (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Stop43 (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Stowarzyszenie Portal Otwartej Informacji (pl)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Sty (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Suomen Yritt�j�t (fi)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Swedish Publishers Association (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Tacd (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Tee (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Telecom Italia (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Telefonica (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Teva (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Tie (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Tsic (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ttvk Finnish Organisation (fi)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Tuotos (fi)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Uk Music (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Unifab (fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Union (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Upu (en, fr)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Vdma (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Ver.di (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Vit Hnilica (cz)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Vno Ncw Mkb Nederland (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Voez (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Vprt (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Vrijschrift (en)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*



Vzbv (de)

Liability of ISPs
*


Cooperation
*


Measures to address infringements
*