ITAC.bill C61 Presentation

8/14/2019 ITAC.bill C61 Presentation

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ITAC: CopyrightReform in Canada

Bill C-61 An Overview

February 23, 2009Barry B. [email protected]

3715529


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What was Bill C-61?

Bill C-61 aimed to:

Amend the Copyright Act in order to implement the World IntellectualProperty Organization Copyright Treaty (WCT) and Performances andPhonograms Treaty (WPPT) (TPMs, distribution right, making availableright)

Create exceptions for certain uses of copyright material for privatepurposes

Create exceptions for Internet Service Providers (ISPs), and

Permit certain uses for educational and research purpose.


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What was Bill C-61?

Bill C-61 aimed to:

Bring our copyright

laws into thedigital age!!


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The Principles Behind the Bill

The rights of those who hold copyright must be balanced with the needsof users to access copyright works.

The Copyright Act must provide clear, predictable and fair rules to allowCanadians to derive benefits from their creations.

The Copyright Act should foster innovation in an effort to attract

investment and high-paying jobs to Canada. Canada must ensure that its copyright framework for the Internet is in

line with international standards.


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The Pre-amble Stated the Bills Objectives to create clear, predictable and fair rules

to support creativity and innovation;

to address opportunities and challengesthat are global in scope for the creationand use of works;

to adopt coordinated approaches tocopyright protection based on

internationally recognized norms; to enhance copyright protection by

adopting the norms set out in the WCT andWPPT;

to provide rights holders with recognition,remuneration and the ability to asserttheir rights.

to enhance users access tocopyright works or other subject-matter;

to enhance the protection of copyright through the recognitionof technological measures andother measures, in a manner thatpromotes culture and innovation,competition and investment in theCanadian economy; and

to bolster Canadas ability toparticipate in a knowledgeeconomy driven by innovation andnetwork connectivity fostered byencouraging the use of digitaltechnologies for research andeducation.


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1. Safe Harbors for ISPs


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1. Safe Harbors for ISPs

Bill C-61 introduced four safe harbors for ISPs:1. A network services exception (ss. 31.1(1))

2. A caching exception (ss. 31.1(2))

3. A hosting services exception (ss. 31.1(4))

4. An exception for information location tools (search engines)(ss. 41.27)


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81. Safe Harbour for ISPs #1:Network Services Exception ss. 31.1(1)

This subsection is intended to provide protectionto intermediaries who act as conduits in relationto the Internet:

A person who, in providing services related tothe operation of the Internet or another digitalnetwork , provides any means for thetelecommunication or the reproduction of awork or other subject-matter through theInternet or that other network does not, solelyby reason of providing those means, infringecopyright in that work or other subject-matter.


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91. Safe Harbour for ISPs #1:Network Services Exception ss. 31.1(1)

The proposed exception is not limited to traditional functions performed bypure ISPs.

Internet or another digital network covers a broad range of technologies.

The phrase providing services could include providing routing services aswell as other telecommunication services (uploading, downloading,

encoding or transcoding, streaming, transmitting etc.) of content. The phrase any means for the telecommunication or the reproduction of a

work is very broad. It would include routers and hardware and allsoftware connection equipment, connectivity services, hosting and otherfacilities and services without which such communications or

reproductions would not occur. SOCAN v CAIP [2004] 2 S.C.R. 427 (Tariff 22) at para. 92 This could include a broad spectrum of activities that facilitatetransmissions of content.

How does it compare to international standards?


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101. Safe Harbour for ISPs #2:Caching Exception ss. 31.1(2)

Subsections 31.1(2) seeks to expand upon the scope of the networkservices exemption by including the act of caching where necessary tomake a telecommunication more efficient:

(2) Subject to subsection (3), a personreferred to in subsection (1) who caches

the work or other subject-matter tomake the telecommunication moreefficient does not, by virtue of that actalone, infringe copyright in the work orother subject-matter.


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The 3 conditions in ss. 31.1(3):

(3) Subsection (2) does not apply unless the person, in respect of thework or other subject matter,

(a) does not modify it;

(b) ensures that any directions related to its caching that areestablished by whoever made it available for telecommunicationthrough the Internet or another digital network, and that lendthemselves to automated reading and execution, are read andexecuted, and

(c) does not interfere with the lawful use of technology to obtain

data on its use.


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The exception is not limited to ISPs. It could apply to all of the entities towhich the network services exception applies to enable them to cache fornetwork efficiency purposes.

This could enable entities that transmit digital content to make and storecopies of a work in server (a cache memory) as an element of theirinfrastructure (any means for the telecommunication or thereproduction of a work) to make transmissions of works more efficient.

These service providers would need to follow the qualifying conditions tofall within the exception.




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131. Safe Harbour for ISPs #3:Hosting Exception ss. 31.1(4)

ss. 31.1(4) is intended to provide an exception for providers of hostingservices:

(4) Subject to subsection (5), a person who, for thepurpose of allowing the telecommunication of a work orother subject-matter through the Internet or anotherdigital network , provides digital memory in which

another person stores the work or other subject-matterdoes not, by virtue of that act alone, infringe copyrightin the work or other subject-matter.

(5) Subsection (4) does not apply in respect of a work or other subject-matter if the person providing the digitalmemory knows of a decision of a court of competent

jurisdiction to the effect that the person who has storedthe work or other subject-matter in the digital memoryinfringes copyright by making the copy of the work or other subject-matter that is stored or by the way in whichhe or she uses the work or other subject-matter.


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The proposed exception is not limited to ISPs or other Internetintermediaries that host websites at the request of subscribers.

The exception applies to any person who provides other entities withdigital memory for the purpose of allowing the telecommunication of awork or other subject-matter through the Internet or another digital

network. The exception applies even if the ISP has actual or constructive notice of

infringement and takes no steps to remove or disable access to thematerial (except a court order).

The exception could immunize any person that makes available any type ofnetworked connected PC, server or online site (all digital memories) forthird parties to store and make available files for file sharing purposes.


1. Safe Harbour for ISPs #3:Hosting Exception ss. 31.1(4)


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151. Safe Harbour for ISPs #4:Information Location Tools ss. 41.27(1)

ss. 41.27(1) is intended to provide the operators of information locationtools with immunity against any remedy other than injunctions:

(1) In any proceedings for infringement ofcopyright, the owner of the copyright in a workor other subject-matter is not entitled, againsta provider of an information location tool whomakes a reproduction of the work or othersubject-matter or communicates thatreproduction to the public bytelecommunication, to any remedy other than

an injunction.


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161. Safe Harbour for ISPs #4:Information Location Tools ss. 41.27(1)

41.27(2): Subsection (1) applies only if the provider:

(a) makes and caches the reproduction in an automated manner;

(b) communicates that reproduction to the public by telecommunication for thepurpose of providing the information;

(c) does not modify the reproduction;

(d) complies with any conditions relating to the making or caching of reproductionsof the work or other subject-matter;

(e) does not interfere with the lawful use of technology to obtain data on the use ofthe work or other subject-matter; and

(f) has not received a notice of claimed infringement relating to the work.

ss. 41.27(3) gives a very broad definition of information location tool as any toolthat makes it possible to locate information that is available through the Internet oranother digital network.


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17Safe Harbour for ISPs #4:Information Location Tools ss. 41.27(1) The proposed exception would apply to any entity that makes it

possible to locate information that is available through the Internet oranother digital network.

The exception would permit caching, making of reproductions, andcommunications to the public with virtually no restrictions as to suchactivities.

Simply being a provider of some searching or indexing capability couldenable that person to create a database and copies of copyrightedmaterials and transmit them to the public.



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Other Features of the ISP Safe Harbours

No eligibilty conditions

Providers full immunities against claims including injunctive relief

Notice and notice

How does this compare to international standards?


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Circumvention of Technological Measures

Objective: In a digital environment, reproductions are easily made anddisseminated. Copyright regimes must provide rights holders with theability to seek remuneration from uses of their works and to authorizeuses that serve their interests. TMs are a mechanism to achieve thisimportant copyright objective. The bill would make it illegal tocircumvent or bypass technologies that control access to protectedmaterial. It would also become illegal to provide, market or import toolsdesigned to enable circumvention.

Government Backgrounder


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3. Technological Protection Measures (TPMs)

Prevent hacking into hardware devices andsoftware to copy or gain access to works

Common TPM devices include FairPlay (iTunes,iPod), Adobe Protected Screening, ContentScrambling System or CSS (DVDs).

Note, the Bill only applies to TPMs that protectaccess or copying of a work (or other subjectmatter) protected by the Copyright Act. It doesnot apply to all TPMs.


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Summary of TPM Provisions

Country Act of Circumvention-Access ControlTechnological Measure

Act of Circumvention-Copyright ControlTechnological Measure

Circumvention Tools-Access ControlTechnological Measure

Circumvention Tools-Copyright ControlTechnological Measure

Criminal Sanctions

United States Prohibited ( 1201 (a)(1))

Not prohibited (by DMCA)Prohibited ( 1201(a)(2)) Prohibited ( 1201(b)) 1204

EU CopyrightDirective

Prohibited (Art. 6(3);Art. 6(1))



Prohibited (Art. 6(3), Art.6(2))

Remedies must beeffective, proportionateand dissuasive. (Art.8)

Canada Prohibited Not Prohibited Prohibited Prohibited Criminal sanctions


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3. Technological Protection Measures (TPMs) technological measure means any effective technology, device or

component that, (a) controls access to a work and whose use is authorized by the

copyright owner; or

(b) restricts the doing of any act referred to in section 3, 15 or 18[infringement] and any act for which remuneration is payable undersection 19 [royalties].

circumvent means,

(a) to descramble a scrambled work or decrypt an encrypted work or tootherwise avoid, bypass, remove, deactivate or impair the technologicalmeasure; and

(b) in respect of a technological measure within the meaning ofparagraph (b) of the definition technological measure, to avoid,bypass, remove, deactivate or impair the technological measure.


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3. Technological Protection Measures (TPMs)41.1 (1) No person shall:

(a) circumvent a technological measure within the meaning of paragraph (a) of the definition technologicalmeasure in section 41;

(b) offer services to the public or provide services if

(i) the services are offered or provided primarily for the purposes of circumventing a technological measure,

(ii) the uses or purposes of those services are not commercially significant other than when they are offeredor provided for the purposes of circumventing a technological measure, or

(iii) the person markets those services as being for the purposes of circumventing a technological measureor acts in concert with another person in order to market those services as being for those purposes; or

(c) manufacture, import, provide including by selling or renting offer for sale or rental or distribute anytechnology, device or component if

(i) the technology, device or component is designed or produced primarily for the purposes of circumventinga technological measure,

(ii) the uses or purposes of the technology, device or component are not commercially significant other thanwhen it is used for the purposes of circumventing a technological measure, or(iii) the person markets the technology, device or component as being for the purposes of circumventing atechnological measure or acts in concert with another person in order to market the technology, device orcomponent as being for those purposes.


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3. Technological Protection Measures (TPMs) 41.1(2) The owner of the copyright in a work, a performers performance fixed in a

sound recording or a sound recording in respect of which paragraph (1)(a) has beencontravened is, subject to this Act and any regulations made under section 41.2,entitled to all remedies by way of injunction, damages, accounts, delivery up andotherwise that are or may be conferred by law for the infringement of copyrightagainst the person who contravened that paragraph.

41.1(3) The owner of the copyright in a work, a performers performance fixed in a

sound recording or a sound recording in respect of which paragraph (1)(a) has beencontravened may not elect under section 38.1 to recover statutory damages from anindividual who contravened that paragraph only for his or her own private purposes.

41.1(4) Every owner of the copyright in a work, a performers performance fixed in asound recording or a sound recording in respect of which a technological measure hasbeen or could be circumvented as a result of the contravention of paragraph (1)(b) or(c) is, subject to this Act and any regulations made under section 41.2, entitled to allremedies by way of injunction, damages, accounts, delivery up and otherwise thatare or may be conferred by law for the infringement of copyright against the personwho contravened paragraph (1)(b) or (c).


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TPM Exceptions and Limitations

1. For law enforcement (s.41.11)

2. For program interoperability (s.41.12)

3. For encryption research (s.41.13)

4. For privacy verification (s.41.14)

5. Security assessment (s.41.15)

6. Perceptual disability (s.41.16)

7. Broadcasting (s.41.17)


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Applicability of TPM ExceptionsException/ Action Law Enforcement Interoperability Encryption

ResearchPrivacy

VerificationSecurity

AssessmentPerceptual Disability Broadcasting

Circumvent Yes Yes Yes Yes Yes Yes Yes

Providing a serviceto circumvent

Yes Yes No Yes Yes Yes

(Person or non-profitorganization only, mustnot unduly impair TPM)

No

Manufacture,import or providetechnology tocircumvent

Yes Yes Yes No Yes Yes

(Person or non-profitorganization only, must

not unduly impair TPM)

No

Exception does notapply if the actconstitutes aninfringement of copyright

No Yes Yes No Yes No No


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3. TPM exception for interoperability41.12 (1) Paragraph 41.1(1)(a) does not apply to a person whoowns a computer program or a copy of it, or has a licence to usethe program or copy, and who circumvents a technologicalmeasure that protects that program or copy for the sole purposeof obtaining information that would allow the person to makethe program and any other computer program interoperable.

(2) Paragraph 41.1(1)(b) does not apply to a person who offersservices to the public or provides services for the purposes ofcircumventing a technological measure if the person does so forthe purpose of making the computer program and any othercomputer program interoperable.

(3) Paragraph 41.1(1)(c) does not apply to a person whomanufactures, imports or provides a technology, device orcomponent for the purposes of circumventing a technologicalmeasure if the person does so for the purpose of making thecomputer program and any other computer programinteroperable and

(a) uses that technology, device or component only forthat purpose; or

(b) provides that technology, device or component toanother person only for that purpose.


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3. TPM exception for interoperability (4) A person referred to in subsection (1) may communicate the information obtained

under that subsection to another person for the purposes of allowing that person to makethe computer program and any other computer program interoperable.

(5) A person to whom the technology, device or component referred to in subsection (3)is provided or to whom the information referred to in subsection (4) is communicatedmay use it only for the purpose of making the computer program and any other computerprogram interoperable.

(6) However, a person is not entitled to benefit from the exceptions under subsections(1) to (3) or (5) if, for the purposes of making the computer program and any othercomputer program interoperable, the person does an act that constitutes aninfringement of copyright.

(7) Furthermore, a person is not entitled to benefit from the exception undersubsection (4) if, for the purposes of making the computer program and any othercomputer program interoperable, the person does an act that constitutes aninfringement of copyright or an act that contravenes any Act of Parliament or any Act ofthe legislature of a province.


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3. TPM exception for encryption research

41.13 (1) Paragraph 41.1(1)(a) does not apply to a personwho, for the purposes of encryption research, circumvents atechnological measure by means of decryption if

(a) it would not be practical to carry out the researchwithout circumventing the technological measure;

(b)the person has lawfully obtained the work, the

performers performance fixed in a sound recordingor the sound recording that is protected by thetechnological measure; and

(c) the person has informed the owner of the copyrightin the work, the performers performance fixed in asound recording or the sound recording who hasapplied the technological measure.


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3. TPM exception for encryption research

(2) However, a person acting in the circumstances referred to insubsection (1) is not entitled to benefit from the exception under thatsubsection if the person does an act that constitutes an infringement ofcopyright or an act that contravenes any Act of Parliament or any Act ofthe legislature of a province.

(3) Paragraph 41.1(1)(c) does not apply to a person referred to insubsection (1) who manufactures a technology, device or component forthe purposes of circumventing a technological measure that is subject toparagraph 41.1(1)(a) if the person does so for the purpose of encryptionresearch and

(a) uses that technology, device or component only for that

purpose; or(b) provides that technology, device or component only for thatpurpose to another person who is collaborating with the person.


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3. TPM exception for personal information41.14 (1) Paragraph 41.1(1)(a) does not apply to a person whocircumvents a technological measure if

(a) the work that is protected by the technological measure is notaccompanied by a notice indicating that its use will permit athird party to collect and communicate personal informationrelating to the user or, in the case where it is accompanied bysuch a notice, the user is not provided with the option toprevent the collection and communication of personalinformation without the users use of it being restricted; and

(b) the only purpose of circumventing the technological measure isto verify whether it permits the collection or communication ofpersonal information and, if it does, to prevent it.

(2) Paragraphs 41.1(1)(b) and (c) do not apply to a person whooffers services to the public or provides services, ormanufactures, imports or provides a technology, device orcomponent, for the purposes of circumventing a technological

measure in accordance with subsection (1), to the extent thatthe services, technology, device or component do not undulyimpair the technological measure.


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3. TPM exception for security

41.15 (1): Paragraph 41.1(1)(a) does not apply to a

person who, with the consent of the owner oradministrator of a computer, computer system orcomputer network, circumvents a technologicalmeasure for the sole purpose of assessing thevulnerability of the computer, system or network orcorrecting any security flaws.


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3. TPM exception for security

(2) Paragraph 41.1(1)(b) does not apply if the services are provided to aperson described in subsection (1).

(3) Paragraph 41.1(1)(c) does not apply if the technology, device orcomponent is manufactured or imported by a person described insubsection (1), or is manufactured, imported, provided including byselling or renting offered for sale or rental or distributed as a service

provided to that person. (4) A person acting in the circumstances referred to in subsection (1) is

not entitled to benefit from the exception under that subsection if theperson does an act that constitutes an infringement of copyright or anact that contravenes any Act of Parliament or any Act of the legislature ofa province.


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More Exceptions Bill C-61 contains a provision which enables the government to enact a

regulation if the government considers that a TPM or class of TPMwould unduly a restrict competition in the aftermarket sector in whichthe TPMs are used. This section is meant to address the Lexmark andChaimberlain cases in the United States. s.41.2(1)

The Bill also permits the addition of classes of exceptions. The criteria

for creating exceptions to the circumvention prohibitions are liberal.There are no governing overriding principle to apply the enumeratedfactors in the subsection. The list of factors resemble the fair dealingexceptions and bring in a fair dealing type argument with respect toproposed exceptions. s.42.2(2)


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4. Making Available Right


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4. Making Available Right

Bill C-61 defines a new right for copyright holders: the "making available"right

This new right for sound recording makers would reserve for them theexclusive right to put their work in a place where it will be available tothe public via telecommunications

As a result, anyone who is not the copyright holder who "makesavailable," without permission, another's copyrighted work would beliable for copyright infringement

Canadian law is not as clear when it comes to making available rightsfor non-sound recordings. There is no explicit making available right forworks.

How can the right be implemented?


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2. Consumer Exceptions


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2. Consumer Exceptions

Bill C-61 would have established three new exceptions to copyrightinfringement related to private, non-commercial uses:

1. Time shifting,

2. Format shifting, and

3. A special format shifting exceptiononly for music.


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2. Consumer Exception #1: Time Shifting

Subsection 29.23(1) creates an exceptionfor an individual to fix a communicationsignal, to reproduce a work or soundrecording that is being broadcast, or to fix

or reproduce a performance that is beingbroadcast, in order to record a program forthe purpose of listening to, or watching itlater.


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This exception is subject to several conditions:

a) The individual must receive the recording program legally

b) The individual does not illegally circumvent a TPM in order to recordthe program

c) The individual does not make more than one copy

d) The individual keeps the recording no longer than necessary to in orderto listen to or watch the program at a more convenient time. (i.e. youcan save it for the weekend, but you cant make your own box set!!)

e) The individual does not give the recording away

f) The recording is used only for private purposes


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ss.29.23(3) states the exception does not apply tothe recording of a program that is communicatedover the Internet, unless it is communicatedsimultaneously via radio or television.

ss.29.23(5) specifies that nothing in the timeshifting exception authorises the recording ofprograms under a network personal video recordingdevice.

This term is defined as a service that allows aperson to store recordings of programs in a serviceprovider as a network facility in order to access

them at a later time A contract made with a video-on-demand provider

will prevail in cases of conflict between theprovider and this exception.

432 C E ti #2 F t


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432. Consumer Exception #2: FormatShifting (non-music)

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2. Consumer Exception #2: Format Shifting ss.29.21(1) would permit an individual to reproduce a work or other subject matter that is

a photograph or is contained in a book, newspaper, periodical or video cassette ontoanother medium or device.

The Governments intent was to restrict this exception to analog films and not digitalmedia or DVDs.

The format shifting exception also contains similar conditions as the time shiftingexception:

(a) the copy of the work of which the reproduction is made is not an infringing copy;(b) the individual legally obtained the work, otherwise than by borrowing it or

renting it, and owns the medium or device on which it is reproduced;

(c) the individual did not circumvent a TPM or cause one to be circumvented,

(d) the individual reproduces the work no more than once for each device that theindividual owns, whether the reproduction is made directly onto the device or ismade onto a medium that is to be used with the device, and

(e) the individual does not give the reproduction away; and

(f) the reproduction is used only for private purposes.

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2. Consumer Exception #2: Format Shifting

For source works that are capable of being

downloaded from the Internet,IF:

1. The individual has downloaded the work fromthe Internet, AND

2. The individual is bound by a contract thatgoverns the extent to which the individual mayreproduce the work

THEN:

The contract prevails over the exception!*

462 Consumer Exception #3:


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462. Consumer Exception #3:Format Shifting of Music



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29.22 (1) It is not an infringement of copyright for an individualto reproduce onto a medium or device a musical workembodied in a sound recording, a performersperformance of a musical work embodied in a soundrecording, or a sound recording in which a musical workor a performers performance of a musical work isembodied, or any substantial part of such a work orother subject-matter

482 C E ti #3


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IF the following conditions are met:

(a)the sound recording is not an infringing copy;

(b)the individual legally obtained the sound recording, otherwisethan by borrowing it or renting it, and owns the medium ordevice on which it is reproduced;

(c)the individual, in order to make the reproduction, did notcircumvent a technological measure or cause one to becircumvented;

(d)the individual reproduces the sound recording no more thanonce for each device that the individual owns, whether thereproduction is made directly onto the device or is made onto amedium that is to be used with the device;

(e)the individual does not give the reproduction away; and

(f)the reproduction is used only for private purposes.

492 C E ti #3


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Internet Contract Prevails:

(2) If the individual has downloadedthe sound recording from theInternet and is bound by acontract that governs the extentto which the individual mayreproduce the sound recording,the contract prevails oversubsection (1) to the extent of any inconsistency betweenthem.

502 C E ti #3


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502. Consumer Exception #3:Format Shifting of MusicOther limitations:

(3) Subsection (1) does not apply if the reproduction is made onto amedium that is governed by Part VIII [blank CDs, casettes].

(4) Subsection (1) does not apply if the individual gives away, rents orsells the sound recording without first destroying all reproductions of itthat the individual has made under that subsection.

(5) Subsection (1) does not apply if the reproduction is made for thepurpose of doing any of the following in relation to the musical work,performers performance or sound recording

(a) selling or renting out, or by way of trade exposing or offeringfor sale or rental;

(b) distributing, whether or not for the purpose of trade;

(c) communicating to the public by telecommunication; or

(d) performing, or causing to be performed, in public.

512 Cons mer E ception #4:


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512. Consumer Exception #4:Statutory Damages Limits

Bill C-61 would have substantially reducedthe potential liability of individuals whoinfringe copyright for private, non-commercial purposes.

Maximum statutory damage of $500 for allinfringements involved in the suit, insteadof existing maximum of $20,000 per workinfringed from s.38.1(1) of the Copyright

Act .



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522. Consumer Exception #4:Statutory Damages Limits

Commercial infringers could still beliable for up to $20,000 in damagesfor each work infringed

This would include posting musicusing the Internet

Statutory damages for makingavailable or TPM circumvention(except for private purposes) wouldalso fall into this upper limit

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VancouverP.O. Box 10424, Pacific CentreSuite 1300777 Dunsmuir StreetVancouver BC V7Y 1K2Tel: 604-643-7100Fax: 604-643-7900

CalgarySuite 3300421 7th Avenue SWCalgary AB T2P 4K9Tel: 403-260-3500Fax: 403-260-3501

TorontoBox 48, Suite 5300Toronto Dominion Bank TowerToronto ON M5K 1E6Tel: 416-362-1812Fax: 416-868-0673

OttawaThe ChambersSuite 140040 Elgin StreetOttawa ON K1P 5K6Tel: 613-238-2000Fax: 613-563-9386

MontralSuite 25001000 De La Gauchetire Street WestMontral QC H3B 0A2Tel: 514-397-4100Fax: 514-875-6246

QubecLe Complexe St-Amable1150, rue de Claire-Fontaine,7e tageQubec QC G1R 5G4Tel: 418-521-3000Fax: 418-521-3099

United Kingdom & Europe5 Old Bailey, 2nd FloorLondon, England EC4M 7BATel: +44 (0)20 7489 5700Fax: +44 (0)20 7489 5777

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