Analysis of answers to IPRED consultation

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Help us map EU lobbies promoting the dangerous war on culture sharing and online repression by analyzing their answers to the consultation on 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. 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 another language.

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

  • Greater 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 against 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?

See templates Bascap, France and Business Europe.


Contents

Analysis of submissions to IPRED consultation

Public authorities

Ak Oesterreich (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Belgium (en)

  • Increased liability of ISPs

On the aspect of the liability of online service providers, we are of the opinion that the current legal framework within the E-commerce Directive provides a good framework. We don’t think that the Enforcement Directive or Trademark Directive should modify the legal regime concerning the liability of intermediaries.

  • Cooperation between ISPs and rights-holders

According to our information, a code of conduct has been signed between the Belgian federation of phonogram producers and the Belgian federation of Service Providers on illegal filesharing via newsgroups. If files are posted on newsgroups without the consent of the rightholders, a procedure is foreseen to remove these files.

  • Repression against further copyright infringements

N/A

Bulgaria (en)

  • Increased liability of ISPs

During the discussions in 2010 and 2011 on the amendment of the Law on Copyright and related rights, (...) proposed changes were aimed at the active involvement of ISPs in cases were there is information/ evidence that infringements are committed by consumers. It was proposed also to regulate the liability of providers in case they were notified of the completion of infringement and have not notified authorities about it.

  • Cooperation between ISPs and rights-holders

The intermediaries should be involved to a greater extent in the prevention or termination of IP infringements. With this respect, different mechanisms could be provided in order to engage their co-operation, including: filtration of content, giving the rightholders the possibility to remove illegal content or request such removal to be done by the intermediaries, as well as possibility to provide information to the authorities about illegal content users and to assist in saving data or other evidence when IP was illegally used.

  • Repression against further copyright infringements

Measures taken at EU level should be related to the liability of Internet service providers/ISPs as one of the actors involved/related to the performance of activity that constitutes or will constitute an infringement of IPR. In this respect, specific mechanisms should be provided for engaging their cooperation, including through content filtering, enabling holders to remove infringing content, or to request ISPs to do so.

Czech Republic (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Danish Chamber Of Commerce (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Denmark (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Deutscher Bundestag (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


European Parliament Committee On Legal Affairs (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Finland Ministry Of Employment And Economy (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


France

  • Increased liability of ISPs

'Les Autorités françaises partagent également le souhait de la Commission d’étudier les possibilités d’impliquer « plus étroitement les intermédiaires, compte tenu de leur position favorable pour contribuer à prévenir les infractions en ligne et à y mettre fin. (...) Toute référence à la directive 2004/48/CE ne peut raisonnablement faire abstraction de la question des catégories d'intermédiaires telles qu'elles résultent de la directive 2000/31/CE sur le commerce électronique. A cet égard, la Commission a entamé également une réflexion sur l’évaluation de la directive 2000/31 relative au commerce électronique, incluant un examen de l’encadrement global des prestataires de services Internet.

Il convient dans ce cadre de réfléchir aux catégories de prestataires techniques et à la portée des régimes qui leur ont été reconnus compte tenu de l’évolution technologique et des usages depuis le moment où la directive a été adoptée. Une articulation étroite entre ces deux exercices (évaluations des directives 2004/48/CE et 2000/31/CE) doit donc être menée, sans pour autant limiter la notion d'intermédiaire au sens de la directive 2004/48/CE à la liste des prestataires intermédiaires définis à l'article 12 de la directive 2000/31/CE.

Summary: Assessment of IPRED should be made in conjunction with the ongoing assessmen of the liability exemptions of eCommerce

  • Cooperation between ISPs and rights-holders

Il pourrait également être envisagé une forme d'obligation de coopération des intermédiaires techniques en vue de prévenir ou de faire cesser une atteinte à un droit de propriété intellectuelle. La coopération des acteurs est un impératif pour la protection des droits de propriété intellectuelle. De ce point de vue, un progrès important consiste en la mise en place de dispositifs d'empreintes qui constituent un moyen intéressant de contribuer à lutter contre le piratage.

Summary: A form of obligation to cooperate (sic) could be considered in order to prevent infringements and address further infringements of intellectual prperty right (...). In this respect, fingerprinting represents an interesting means of fighting against piracy.

  • Repression against further copyright infringements

Un progrès important consiste en la mise en place de dispositifs d'empreintes qui constituent un moyen intéressant de contribuer à lutter contre le piratage. (...) La procédure dite de "notification et retrait" pourrait être précisée afin d'indiquer qu'elle prévoit d'éviter la nouvelle remise en ligne par un autre utilisateur du même contenu contrefaisant le droit d'auteur ou les droits voisins (procédure "notice and keep off" ou "notice, take down & stay down"). Cette mesure n'est qu'un exemple qui ne doit pas limiter une réflexion plus large sur les mesures préventives de filtrage et de détection des contrefaçons.

Summary: Notice and Takedown procedure should be completed to stress that intermediaries should avoid any reposting by another user of the same copyright infringing content. This measure is only one example that should not hamper a broader reflexion on preventive measures of filtering and detecting infringements.

Germany (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Hadopi (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Hungary Ministry Public administration And Justice (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ireland (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Italy Ministry Of Agrifood (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Italy Office Of The Prime Minister (it)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Latvia (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Lithuania Ministry Culture (lt)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Malta (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Netherlands Ministry Security Justice (nl)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Poland Ministry Culture (en, pl)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Portugal (pt)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Romania (en, ro)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Slovakia (sk)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Spain Ministry Of Justice (es)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Uk Governement

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Wko Austria (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]

Organisations

Act (en)

  • Increased liability of ISPs

For example the rules on disclosure of information about infringing subscribers and liability and the definition of intermediaries. In our opinion it would be useful to clarify this definition at European level, by means of a Commission statement. This could update the definition to mirror the evolution of the internet in the last ten years, and prevent parties who are not neutral toward the illegal content they carry, as they are directly and indirectly exploiting it, from availing themselves of the limitations on liability provided for under the E-commerce directive.

  • Cooperation between ISPs and rights-holders

The political message should however be clear: both rightsholders and ISPs have a role to play in tackling the theft of content online. At national level, many of our member companies are engaged in negotiations as to the concrete form this can take. For example, in the UK, under a voluntary code that is under discussion, content owners would pass evidence of mass illegal filesharing sites to ISPs, which would then take action against those sites. This site-blocking initiative was described as “interesting” by an ISP source quoted in the press and has the advantage of focussing only on mass illegal filesharing sites, thereby avoiding targeting of end users. This form of constructive negotiation among ISPs and the content industry has not yet in every Member State led to more cooperation for the fight against piracy, for example in Germany. But the form of constructive negotiation is something which should be encouraged and it is to be regretted that such a dialogue could not be continued at European level with the recent abandonment of the Stakeholders’ Dialogue on Illegal Uploading and Downloading of Content. The fact that negotiations are apparently continuing at national level is nevertheless positive.

There is some evidence at national level that, despite the breakdown of talks in Brussels, ISPs and rightsholders can co-operate in fight against commercial-scale piracy, i.e., that an update of the provisions can and should be done within the existing framework and without necessarily unpicking the entire structure of the e-commerce directive. In this way, we are confident that the over-riding needs of our industry can be met: for investment in content to be protected and for anti-piracy measures targeted at those activities where commercial damage is being caused to be further promoted at the EU and international level.

  • Repression against further copyright infringements

N/A

Aepoc (en)

Short Summary of the organisation AEPOC (www.aepoc.org) represents major players (including manufacturers, platform operators, conditional access vendors, and broadcasters) involved in the distribution of paid-for content in the fight against audiovisual piracy.

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

As a general principle AEPOC considers that organisations which gain directly from providing a commercial service to an infringing activity could be subject to legal action under the Directive. For this purpose intermediaries could include online marketplaces and payments services.Such organisations may not be aware initially that the user of the service is infringing IPR and AEPOC suggests that, as a minimum, once legal action has been taken successfully against the illegal activity, then any repetition of the service could be considered unlawful.

  • Chosen sentences :

As mentioned above piracy is now synonymous with cybercrime.

  • Other :

AEPOC would draw the Commission’s attention to the phenomenon of “card-sharing” or “control word sharing”. Card sharing is a method by which independent receivers obtain simultaneous access to pay television services, using one legitimate conditional access subscription card.

Afep (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Aim (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Aippi Belgium (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Aippi Finland (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Aippi General Secretariat (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Allegroup (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Alliance Against Ip Theft (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Alstom (en)

Alstom does not consider directly the problem of copyright infringement. Its participation to the IPRED revision process concerns industrial issues, namely competition with foreign companies that infringe on its industrial property, patent rulings, and trade secrets. Most of its answer is indeed a statement from the "Trade Secrets & Innovation Coalition" (TSIC), a lobby that gathers Alstom, CEFIC, DuPont de Nemours, Michelin, Nestlé, Procter & Gamble and Solvay, inter alia.

The purpose of the TSIC lobby is to have trade secrets acknowledged as a form of IPR protected by the IPRED directive. In their opinion, "know-how"s should be protected as patents are. This is a dangerous trend. While patents have been filed and published, as a counterpart to the public for the granted monopoly, know-hows can be freely rediscovered by third parties that acquire knowledge by self experience. Being able to sue a third party that gains some knowledge on the basis that this knowledge is considered a trade secret is mere nonsense. A company uses either the patents and trades off publicity for secrecy, or else uses trade secrets without further protection. One cannot have both the butter and the money for the butter.

Alstom also wishes a black list of "IP-unfriendly" foreign companies, that could be used to ban their imports without judging whether the imported goods actually infringe or not. Chinese companies are specifically targeted.

Alstom wishes to have a unified patent court at the EU level.

  • Increased liability of ISPs

N/A

  • Cooperation between ISPs and rights-holders

N/A

  • Repression against further copyright infringements

N/A

Andema (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Anica Fapav Univideo (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Apm (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Apram (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


April (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Apt (it)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Association Francaise Ubuntu (fr)

  • Increased liability of ISPs

[insert quote here] NO

  • Cooperation between ISPs and rights-holders

[insert quote here] NO

  • Repression against further copyright infringements

[insert quote here] NO

Assotelecomunicazioni Asstel (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Aukro Bulgaria (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Aukro Czech Rep (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Aukro Slovakia (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Bascap (en)

  • Increased liability of ISPs

Some Member States have taken the view that injunctions against intermediaries are only allowed if the intermediary itself is found to be aiding and abetting or otherwise is held liable for its customer’s or user’s infringement. Several Member States similarly restrict the availability of interlocutory injunctions under Article 9 of the Directive. There is no mention of any such restrictions in the Directive, and these only encourage unnecessary litigation against intermediaries. It would be helpful to make clear that permanent and interlocutory injunctions against third-party intermediaries do not depend on the liability of the intermediary.

  • Cooperation between ISPs and rights-holders

The Commission’s and Member States’ continued efforts to push good-faith negotiations and otherwise ensure appropriate co-operation between rights owners and various types of intermediaries will be vital for developing further solutions to the complex current and future forms of on-line counterfeiting and piracy.

  • Repression against further copyright infringements

There has been some confusion in several cases, some pending before the Court of Justice, as to whether injunctions can be issued only to prevent a specific infringer from continuing the particular infringement identified in the case. Given the speed of repeated infringements and the cost of securing repeated injunctions, it would be helpful to clarify that injunctions need not be so limited, but in appropriate cases can also cover, for example, future activities of that infringer related to the same or other titles/brands of the rights owner.

Bdwi (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Bdzv Vdz En (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Benelux Verenging Voor Merken En Modellenrecht (nl)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Beuc (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Bits Of Freedom (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Boev (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Bouygues (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Brein (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Bsa (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Bskyb (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Businesseurope (en)

  • Increased liability of ISPs

Any future revision of the enforcement directive should ensure coherence with the relevant provisions of the e-commerce directive including who qualifies for the liability exemptions and also with the relevant provisions of the data privacy directives.

  • Cooperation between ISPs and rights-holders

Closer cooperation between all authorities and actors involved including intermediaries is necessary.

  • Repression against further copyright infringements

NO

Bwin Party (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Cable Europe (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Cable Europe Ecta Etno Euroispa Gsma (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ccia (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ccip (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ccip Fiche Synthese (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Cefic (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ceipi (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Cepi Fera Fiad Fiapf Ivf (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Chartered Institute Of Pa (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Cmba (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Cnac (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Colipa (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Comite Colbert (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Confindustria (it)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Confindustria Servizi Innovativi E Tecnologici (it)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Constant (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Consumer Focus (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Dacs (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Danish Copyright Council (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Danish Patent Agents Association (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Danske Universiteter (dk)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Dbf (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Deutsche Patentanwaltskammer (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Deutsche Patentanwaltskammer Cover (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Deutsche Post Dhl (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Deutsche Telekom (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Deutscher Anwaltverein (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Deutscher Markenverband (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Dihk (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Eaea (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ebay (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ebca (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ebf Contribution (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Eccia (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ecta (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Edima (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Edps (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Edri (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Efpia (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Egdf (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Egeda (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Egma (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Eli Lilly (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Emeca (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Enpa50 (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Epa (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ericsson (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Esa (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Etno (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Eurocopya (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Euroispa (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


European Fashion Council (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


European Producers Club (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


European Publishers Council (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Faep (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Fast

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Fastweb (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Fdn (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Fep (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Fesi (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ffii (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Finnish Commerce Federation (fi)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]



Fimi (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Fondation Giacometti (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Fondation Hartung-bergman (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Fondation Le Corbusier (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Fox International Channels (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Fsfe (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Gema (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Gesac (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Gi Dpi (es)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Giart (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Gleiss Lutz (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Google (en)

"Google believes that there is no case for a re-opening of the Directive at this stage" (p. 10).

"The Report considers that the Directive “was not designed with the challenge posed by the Internet to the enforcement of intellectual property rights in mind”, [...] As explained earlier the IPRED provisions have been designed to balance the respective interests of right owners, users and intermediaries, including on the Internet" (p. 9-10).

  • Increased liability of ISPs

"Just like in the offline environment, right owners have the primary responsibility to enforce their rights, as they are in a unique position to determine these rights and when they are effectively infringed." (p. 11).

"Voluntary measures and collaboration with IP owners undertaken by responsible ISPs to identify or prevent certain activities that may contravene applicable laws or the service’s terms of use should in no case be considered as constituting “actual knowledge” engaging the liability of ISPs" (p. 11).

"Injunctions imposed on ISPs to stop or prevent IP infringement should in no case call into question the prohibition of general monitoring obligation established in Article 15 of the e-commerce Directive and lead to an obligation for ISPs to filter their services." (p. 11).

"Making ISPs liable for any content accessed or made available through their services, would call on ISPs to systematically monitor this content. This would contradict the provisions set out in Article 15 of the e-commerce Directive, establishing that intermediaries have no general obligation to monitor the information that they transmit or store nor a general obligation to seek facts or circumstances indicating illegal activity" (p. 2).

  • Cooperation between ISPs and rights-holders

"Google believes it is key for the Commission to focus on ways to facilitate copyright licensing to value content online, as opposed to additional measures on IP enforcement" (p. 5).

"[...] it is important to keep in mind that the use of content identification technologies can at best allow the identification of copyright protected content that have been identified as such by the rights holders. They cannot make the distinction between an unauthorised use of a copyright protected content, and the legitimate use of this content by users falling under the scope of a copyright exception or a license" (p. 9).

"In a technological and legal environment where a great amount of content is protected by copyright, there is no automated way to determine whether a particular use is licensed or covered by an exception to copyright law", e.g.: "Similarly, pop sensation Justin Bieber recently uploaded his own music video to YouTube, only to have it mistakenly targeted for removal by his record label" (p. 2).

"For Google’s part, we have clear policies about abuse of our services to infringe IP. We have implemented copyright notice-and-takedown provisions across our services, as well as forms to notify us of sales or advertisement of counterfeit goods through our services" (p. 3).

  • Repression against further copyright infringements

"Permanent injunctions imposing general obligation to filter on intermediaries, would call into question the balance established between the interests of right owners and intermediaries, as well as the fundamental rights of the users such as the right to freedom of expression or telecommunication secrecy" (p. 8).

"[Regarding] permanent injunctions imposing general obligation to filter on intermediaries [...] while the technical feasibility or efficiency of such a monitoring is actually doubtful and contested, the use of filtering technologies entails important risks for the development of information society services. Filtering [...] risks degrading the quality and users’ experience for perfectly legitimate online services, raising serious concerns for competition and innovation".

"[...] injunctions should not be imposed that the intermediary is incapable of complying with and in particular, injunctions should not be made that breach Article 15 of the e-commerce Directive'"" (p. 9).

"[...] consider YouTube’s “Content ID”, which uses audio and video identification technology developed internally specifically for use on YouTube. This technology scans every video uploaded to YouTube and compares each with a library of more than 4 million reference files provided by participating copyright holders. If a match is identified, the system automatically applies the content owner’s instructions about what to do: whether to block the matching video from appearing on YouTube, track how users are watching it, or monetize the video by permitting advertisements to be shown alongside it." (p. 4).

Grupa Allegro (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Grur (de, en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Gsma europe (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Hai Europe (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Icc (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Icmp (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ifpi (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ifrro (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Indicam (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Inta (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Intel (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Internet Society (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Internet Society Poland Panoptykon (pl)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ip Federation (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ipo (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Isfe (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ispa Austria (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ispa Belgium (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Iuridicum Remedium (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Johan Schl�ter Advokatfirma (dk, en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Kepka (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Kopiosto (fi)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ksb Sas (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


La Quadrature Du Net (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


La-ex Fcforum (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Les (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Lesi (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Lyhty (fi)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Marques (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Medef (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Mediaset (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Microsoft (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Mih (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Mpa (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Nuovo Imaie (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Nurpa (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


ORG (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Parti Pirate (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Philips (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Pike (pl)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Pin Sme (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Pirelli (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ppl Uk (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Publishers Association (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Qdlaty (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Qxl Ricardo Denmark (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Qxl Ricardo Greece (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Rga (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Rim (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Royal Tnt Post (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Royal Tnt Post Taxud (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Saa (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Sabam Form figures (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Sabam Questionnaire (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Sacd (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Sacg (en)

  • Increased liability of ISPs

SACG agrees to the recommendation to provide for general sanctions for failure to comply with orders for ISP. There is a need to ensure that court orders imposing an injunction on a defendant are subject to appropriate penalties for non-compliance. ( 3§8)

  • Cooperation between ISPs and rights-holders

SACG supports the recommendation to implement a possibility of requesting the seizure or delivery up of goods suspected of infringing IP rights in all IP infringement cases. In principle, the right-holders should be able to request the precautionary seizure or delivery up of goods suspected of infringing his IP rights, in all IP cases, not just those where the infringement is committed on a commercial scale. (3 § 4)

SACG agrees to the need to clarify the relation between injunctive reliefs under the Enforcement Directive and Directive 2001/29/EC and data-protection rules. (3§5)

  • Repression against further copyright infringements

it is SACG‟s opinion that it should be further clarified that destruction is the prevailing corrective measure that should be ordered and that secondary use, e.g. removal of trademark, should be a secondary option which is only admitted in special cases. In SACG‟s opinion it should be clarified that secondary use should be admitted only in special cases, namely only when the right holder 1) has agreed to it and 2) there is considered no risk that the products reach the market again, and 3) there is a specific public interest to avoid destruction. (2§2)

SACG suggests that it must be made clear that reasonable compensation/royalty for the use of an intellectual property right should be awarded as a complement to compensation for damages (in particular lost profits) and not as an alternative. Such clarification would increase damage amounts and its dissuasive effects. (5§4)

Sazas (si)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Sek (fi)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Sroc (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Stm (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Stop43 (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Stowarzyszenie Portal Otwartej Informacji (pl)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Sty (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Suomen Yritt�j�t (fi)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Swedish Publishers Association (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Tacd (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Tee (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Telecom Italia (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Telefonica (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Teva (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Tie (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Tsic (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ttvk Finnish Organisation (fi)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Tuotos (fi)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Uk Music (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Unifab (fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Union (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Upu (en, fr)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Vdma (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Ver.di (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Vit Hnilica (cz)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Vno Ncw Mkb Nederland (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Voez (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Vprt (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Vrijschrift (en)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]


Vzbv (de)

  • Increased liability of ISPs

[insert quote here]

  • Cooperation between ISPs and rights-holders

[insert quote here]

  • Repression against further copyright infringements

[insert quote here]