Analysis of answers to IPRED consultation

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.

Ak Oesterreich (de)

 * ak_oesterreich_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Belgium (en)

 * belgium_en.pdf

''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.''
 * Increased liability of ISPs

''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.''
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Bulgaria (en)

 * bulgaria_en.pdf

''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.  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.''
 * Increased liability of ISPs
 * Cooperation between ISPs and rights-holders

''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.''
 * Repression against further copyright infringements

Czech Republic (en)

 * czech_republic_en.pdf

There are some rulings on online service providers liability (e.g. C-236-238/08 (Google France a Google France SARL v. Louis Vuitton Malletier SA a další), however, some proceedings concerning copyright and related rights ́ infringements and ISPs liability are still pending. Therefore, it seems to be logical to wait for rulings also in these pending cases before any further considerations is presented. 1.5
 * Increased liability of ISPs

For the time being it might be possible to consider covering liability of the online service providers also in the enforcement directive.

N/A
 * Cooperation between ISPs and rights-holders

I will be necessary to consider a possibility to introduce some measures for better enformcement of IPRs on the Internet, especially to solve problems with anonymity etc 1.1
 * Repression against further copyright infringements

Danish Chamber Of Commerce (en)

 * danish_chamber_of_commerce_en.pdf

The Danish Chamber of Commerce cannot support a proposal where authorities and copyright owners are equipped with further means than the present injunction possibilities toward any third party to limit infringement of intellectual rights.

N/A
 * Increased liability of ISPs

N/A
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Denmark (en)

 * denmark_en.pdf

The Commission should take in to consideration, that limitations to the liability of online ser- vice providers are regulated in the E-Commerce Directive (2000/31/EC) when the role of in- termediaries is considered in connection with the revision of the Enforcement Directive. 1.3
 * Increased liability of ISPs

nvolvement of intermediaries (e.g. transport service providers, Internet platforms, ISPs) to a greater extent in the prevention or termination of IP infringements should be reasonable and balanced in relation to their possibilities’ of carrying out their businesses. 4.5
 * Cooperation between ISPs and rights-holders

The Danish Government therefore supports the Commission’s endeavour to limit the increasing problem of IPR infringements in the digital environment. 1.1
 * Repression against further copyright infringements

Deutscher Bundestag (de)

 * deutscher_bundestag_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

European Parliament Committee On Legal Affairs (en)

 * european_parliament_committee_on_legal_affairs_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Finland Ministry Of Employment And Economy (en)

 * finland_ministry_of_empl_and_economy_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

France

 * france.pdf

'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.''
 * Increased liability of ISPs

''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

''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.''
 * Cooperation between ISPs and rights-holders

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.

''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.''
 * Repression against further copyright infringements

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)

 * germany_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Hadopi (fr)

 * hadopi_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Hungary Ministry Public administration And Justice (en)

 * hungary_ministry_public_ administration_and_justice_en.pdf

Hungary believes that the issue of the liability of ISPs should be addressed in the E-commerce Directive rather than in the Enforcement Directive. This, of course does not mean that Hungary urges the amendment of the E-commerce Directive – we are just indicating the right legislative location of the relevant provisions. 1.3
 * Increased liability of ISPs

The purpose of the above is that Article 5 of the E commerce Directive, which prescribes for service providers to render certain information easily, directly and permanently accessible to the recipients of the service and the competent authorities, be applicable to persons carrying out file sharing activities. The Hungarian IP acts transposing the Enforcement Directive enable judicial authorities to order online service providers, regardless of their liability, to disclose information. With its rights infringed, the right holder may demand that the infringer give information on the identity of third persons involved in the production and distribution of the infringing goods or in the provision of infringing services and of their channels of distribution. 1.4
 * Cooperation between ISPs and rights-holders

Right holders’ associations also suggested the extension of the list of measures to be applied with respect to infringements in an online environment. The proposed measures include - impeding the accessibility of the websites (DNS and IP address), - blocking of the domain names used for illegal services, - introduction of filtering systems in compliance with the provisions of Directive  2001/29/EC (Infosoc Directive) requiring effective enforcement measures but not falling within the scope of the prohibition of general monitoring enshrined in the E- commerce Directive, - making the filtering / restriction possible on the basis of the volume of the traffic, - adoption of a gradual response system similar to a HADOPI system in France, - accepting the negative statement of collective right management societies as evidence of the service’s illegality (in case of use falling under extended collective right management). 1.2
 * Repression against further copyright infringements

Ireland (en)

 * ireland_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Italy Ministry Of Agrifood (en)

 * italy_ministry_of_agrifood_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Italy Office Of The Prime Minister (it)

 * italy_office_of_the_prime_minister_it.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Latvia (en)

 * latvia_en.pdf

Latvia agrees that there is a need to provide in the legal framework, namely in the Enforcement Directive, rules regarding the liability of online service providers as well as to define the term an intermediary whose services are being used by a third party to infringe the right holder’s industrial property right. Thus Latvia supports the necessity to evaluate the development of explicit rules that would enable authorities to order online service providers (intermediaries), regardless of their liability, to disclose the information relating to individuals who have allegedly committed IPR infringement. §6
 * Increased liability of ISPs

In addition Latvia welcomes the need to involve intermediaries to a greater extent in the prevention or termination of IPR infringements. Intermediaries, for example, can accumulate and gather information from Internet users regarding possible IPR infringements and to report about possible infringements to state law enforcement agencies. § 14
 * Cooperation between ISPs and rights-holders

Priority of Latvia would be to provide effective and proportionate measures which would prevent further infringements. The most appropriate measures in the context of digital environment in the opinion of Latvia would be provisional measures, such as injunction an injunction aimed at prohibiting the continuation of the infringement and assurance of evidence §5
 * Repression against further copyright infringements

Latvia also agrees that there is a need to ensure that personal computers can be searched/ seized in order to establish evidence for an IPR infringement committed via the Internet, butonlyonthe basis of the court decision. §9

Therefore, in practice judges are looking for balance of interests between the legal framework for the privacy, protection of personal data, commercial secret and rights to the request of information. Latvia does not find the need to amend the Enforcement Directive in order to accommodate such conflicts §16

Lithuania Ministry Culture (lt)

 * lithuania_ministry_culture_lt.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Malta (en)

 * malta_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Netherlands Ministry Security Justice (nl)

 * netherlands_ministry_security_justice_nl.pdf
 * netherlands_ministry_security_justice_annex1_nl.pdf
 * netherlands_ministry_security_justice_annex2_nl.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Poland Ministry Culture (en, pl)

 * poland_ministry_culture_en.pdf
 * poland_ministry_culture_pl.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Portugal (pt)

 * portugal_pt.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Romania (en, ro)

 * romania_en.pdf
 * romania_ro.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Slovakia (sk)

 * slovakia_sk.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Spain Ministry Of Justice (es)

 * spain_ministry_of_justice_es.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Uk Governement

 * uk_governement.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Wko Austria (de)

 * wko_austria_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Act (en)

 * act_en.pdf

''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.''
 * Increased liability of ISPs

''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.''
 * Cooperation between ISPs and rights-holders

''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.''

N/A
 * Repression against further copyright infringements

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.


 * aepoc_ en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

''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.''
 * Repression against further copyright infringements

As mentioned above piracy is now synonymous with cybercrime.
 * Chosen sentences :

''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.''
 * Other :

Afep (fr)

 * afep_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Aim (en)

 * aim_en.pdf

"[...] it may also be helpful to consider introducing the principle of joint liability between intermediaries to encourage all intermediaries in the chain of contracts to feel responsible to check whether their counterparts follow the law." (p.3)
 * Increased liability of ISPs

"As highlighted in the Internet section, we fully agree that injunctions should not depend on the liability of the intermediary..." (p.9)

" [...] Injunctions against intermediaries are not intended as a penalty against them, but are simply based on the fact that such intermediaries (e.g. Internet service providers) are in certain cases in the best position to stop or to prevent an infringement..." (p.9)

[insert quote here]
 * Cooperation between ISPs and rights-holders

"All commercial parts of the supply chain should be involved in the production of information and evidence and, if appropriate, be held liable for costs where they refuse to do so, have received funds and/or otherwise have profited from the infringement. This includes Internet intermediaries including ISPs, ... " (p.16)
 * Repression against further copyright infringements

Aippi Belgium (en)

 * aippi_belgium_en.pdf

"The European legislator should clarify that injunctions against intermediaries are possible under the Enforcement Directive, irrespective of their (lack of) liability under Directive 2000/31/EC." (p.10)
 * Increased liability of ISPs

"[...] Regarding Internet Service Providers (“ISPs”), we are of opinion that no commercial scale conditions should be applicable." (p.7)

[insert quote here]
 * Cooperation between ISPs and rights-holders

"[...] The European legislator should take measures to facilitate the cross-border collection of evidence and better adapt the current measures to the online world." (p.7)
 * Repression against further copyright infringements

Aippi Finland (en)

 * aippi_finland_en.pdf

N/A
 * Increased liability of ISPs

N/A
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Aippi General Secretariat (en)

 * aippi_general_secretariat_en.pdf
 * aippi_general_secretariat_annex1_q163 _en.pdf
 * aippi_general_secretariat_annex2_q216_resolution_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Allegroup (en)

 * allegroup_en.pdf

…"It should be also underlined that Internet platforms, which are considered by the European Commission as intermediaries as defined by Directive 2004/48, are providers solely from the technical point of view, and their employees lack sufficient knowledge to carry out a thorough legal analysis on whether a given material infringes the law or is subject to one of many issues regarding intellectual property rights." (p.6)
 * Increased liability of ISPs

N/A
 * Cooperation between ISPs and rights-holders

"Allegroup.hu as the most significant player in the Hungarian e-commerce market, and part of MIH Group, strongly suggests that specific issues regarding the electronic economy in a regulation concerning intellectual property protection of general application is not necessarily to be adopted." (p.7)
 * Repression against further copyright infringements

Alliance Against Ip Theft (en)

 * alliance_against_ip_theft_en.pdf

N/A
 * Increased liability of ISPs

"More collaboration from these intermediaries would greatly help to reduce the risk to consumers of purchasing illicit products and services." (p.3)
 * Cooperation between ISPs and rights-holders

"The Alliances encourage the Commission to continue its support for voluntary dialogues between intermediaries and rights holders." (p.4)

N/A
 * Repression against further copyright infringements

Alstom (en)

 * alstom_en.pdf

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.

N/A
 * Increased liability of ISPs

N/A
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Andema (en)

 * andema_en.pdf

"Involving Internet intermediaries is of particular importance in this process and we welcome the Commission’s recognition in the Report that “given intermediaries' favourable position to contribute to the prevention and termination of online infringements, the Commission could explore how to involve them more closely.” (p.2)
 * Increased liability of ISPs

"Intermediaries, including Internet Service Providers (ISPs), are therefore important partners for right holders in protecting consumers from fraud, illicit practices and counterfeit or other infringing goods or content and, as the Commission rightly points out, it should explore how to involve these intermediaries more closely in the enforcement process." (p.2)
 * Cooperation between ISPs and rights-holders

"The duty of care could, for example, require online service providers to take all reasonable measures to detect and prevent IP infringements on their services." (p.3)
 * Repression against further copyright infringements

"It would be useful to obtain injunctions not only prohibiting infringements, but also for preventive measures for future infringements, such as the obligation to use filters." ( p.4)

Anica Fapav Univideo (en)

 * anica_fapav_univideo_en.pdf

ISPs whose services are used in infringing activities have an obligation to prevent such infringements, regardless of their liability for the underlying infringements. It is not a matter of reopening the debate on, or affecting, the liability status of ISPs, but rather of recognizing that they are the best placed to act for the purpose of preventing (and/or terminating) an IPRs infringement act from taking place through a ISPs’ service. (p.3)
 * Increased liability of ISPs

[...] we reiterate its support to the Commission’s initiative to review the Directive and recommend focusing the efforts on the enforcement problems related to the Internet. We in particular call on Commission to improve, in collaboration with stakeholders’ representatives, civil enforcement of IPRs and to resolve a number of difficulties to ensure further protection against online infringement, including efficient combating of piracy and other forms of unauthorized reproduction. (p.4)
 * Cooperation between ISPs and rights-holders

Moreover, special measures should be put in place for search engines and social networks, as these enable the storage of illicit content for long periods and may encourage illicit behaviours, such the online use and distribution of content protected by copyright. (p.3)
 * Repression against further copyright infringements

Apm (de)

 * apm_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Apram (fr)

 * apram_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

April (fr)

 * april_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Apt (it)

 * apt_it.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Association Francaise Ubuntu (fr)

 * association_francaise_ubuntu_fr.pdf

[insert quote here] NO
 * Increased liability of ISPs

[insert quote here] NO
 * Cooperation between ISPs and rights-holders

[insert quote here] NO
 * Repression against further copyright infringements

Assotelecomunicazioni Asstel (en)

 * assotelecomunicazioni_asstel_en.pdf

"Since it cannot reasonably be argued that the IPRED takes precedence over the ECD or that copyright prevails over rights to e-Commerce and freedom of communications, ASSTEL calls on the Commission to avoid any interpretations that would jeopardize the limited liability regime of ISPs." (p.4)
 * Increased liability of ISPs

"A conservative or – worse – repressive approach, mainly based on increasing sanctions, is costly, in the short run, and losing, in the long one: due to many reasons concerning technological innovation’s potential and timing, and competition between countries, ASSTEL is concerned about a restrictive approach eventually leaving the way for a residual role of the Union in the on-line markets." (p.4)

[insert quote here]
 * Cooperation between ISPs and rights-holders

"Nowadays, as shown also by recent studies, illegal behaviour is often due to the lack of a legal attractive offer with the same features; to put in place the juridical tools to increase this legal offer would be the correct action against intellectual property rights infringement on the electronic communications networks and in favour of economic development." (p.3)
 * Repression against further copyright infringements

Aukro Bulgaria (en)

 * aukro_bulgaria_en.pdf

"The Report and, particularly, the Staff Working Paper then state that the tools currently available to right holders (provisional measures, precautionary measures and permanent injunctions) are not powerful enough to combat online infringements, and that the Commission should explore how online intermediaries can contribute to the prevention and termination of infringements, "given intermediaries' favourable position". (p.4)
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Aukro Czech Rep (en)

 * aukro_czech_rep_en.pdf

"The Report wrongly suggests that Directive 2000/31/EC protects online intermediaries against liability. It should be borne in mind that in principle liability involves illegal action of a given entity. Therefore, referring to a statutory extension of liability onto online intermediaries which do not initiate illegal contents as protection against liability seems to be contrary to generally applicable, universal legal rules." (p.5)
 * Increased liability of ISPs

"It is even more significant that although the Report and the Commission staff Working Document discuss the fundamental user’s right to privacy, they fail to mention the freedom of expression, which is also a fundamental right. If online intermediaries were obligated by courts to actively search their systems and establish whether a given material is owned by a right holder and potentially infringes certain rights, there would occur a serious risk of censorship towards users. Such general court injunction will encourage online intermediaries to remove materials the illegal character of which is not certain." (p.8)

"The condition of “being aware” balances the protection against liability with the interest of right holders by allowing the right holders to inform online intermediaries about illegal contents who will be then motivated to remove the illegal contents in order to maintain the right to protection against liability." (p.6)
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Aukro Slovakia (en)

 * aukro_slovakia_en.pdf

"The Report wrongly suggests that Directive 2000/31/EC protects online intermediaries against liability. It should be borne in mind that in principle liability involves illegal action of a given entity. Therefore, referring to a statutory extension of liability onto online intermediaries which do not initiate illegal contents as protection against liability seems to be contrary to generally applicable, universal legal rules." (p.5)
 * Increased liability of ISPs

"It is even more significant that although the Report and the Commission staff Working Document discuss the fundamental user’s right to privacy, they fail to mention the freedom of expression, which is also a fundamental right. If online intermediaries were obligated by courts to actively search their systems and establish whether a given material is owned by a right holder and potentially infringes certain rights, there would occur a serious risk of censorship towards users. Such general court injunction will encourage online intermediaries to remove materials the illegal character of which is not certain." (p.8)

"The condition of “being aware” balances the protection against liability with the interest of right holders by allowing the right holders to inform online intermediaries about illegal contents who will be then motivated to remove the illegal contents in order to maintain the right to protection against liability." (p.6)
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Bascap (en)

 * bascap_en.pdf

''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.
 * Increased liability of ISPs

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.
 * Cooperation between ISPs and rights-holders

''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.''
 * Repression against further copyright infringements

Bdwi (de)

 * bdwi_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Bdzv Vdz En (de)

 * bdzv_vdz_en_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Benelux Verenging Voor Merken En Modellenrecht (nl)

 * benelux_verenging_voor_merken_en_modellenrecht_nl.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Beuc (en)

 * beuc_en.pdf

"BEUC is seriously concerned with the European Commission’s assessment that the closer involvement of ISPs in the fight against IPR infringements is the recommended way forward." (p.9) "A simple warning by a copyright owner that specific content is allegedly infringing copyright should never be considered conclusive evidence entailing the liability of the internet provider." (p.10) "BEUC is opposed to a wide interpretation of the provision on injunctions which would require ISPs to monitor content and prevent infringements in the future. Such an extensive interpretation conflicts with the prohibition of general monitoring as outlined in Article 15 of the e-commerce Directive23 and should therefore be rejected." (p.10)
 * Increased liability of ISPs

"BEUC is concerned about the shift of enforcement from courts to the hands of intermediaries and right holders. Whereas a court proceeding provides safeguards of due process and careful analysis of legal questions, enforcement by ISPs deprives the user of a number of fundamental rights, including the right to a presumption of innocence, the right to be heard, the right to due process, the right to privacy and confidentiality of communications." (p.11)
 * Cooperation between ISPs and rights-holders

"... In particular, the main question is whether copyright enforcement should take precedence over the competing objective of preserving freedom of communication and expression on the internet. Intellectual property should serve the dual role of providing incentives and facilitating dissemination. This equilibrium needs to be reflected in related public policy initiatives and legislative proposals." (p.3)
 * Repression against further copyright infringements

Bits Of Freedom (en)

 * bits_of_freedom_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

"We recommend to study the impact on fundamental rights of the enforcement practice in the EU and where necessary restrict the scope of enforcement possibilities envisaged in IPRED in light of the findings of such a study, especially with regard to individual internet users exchanging information without a commercial profit motive." (p.4)
 * Repression against further copyright infringements

Boev (de)

 * boev_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Bouygues (fr)

 * bouygues_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Brein (en)

 * brein_en.pdf

[insert quote here]
 * Increased liability of ISPs

"To a large extent this frustrating problem for rights holders could be solved by the implementation of an explicit obligation for hosting ISP’s to suspend their services to customers of whom they become aware that they have supplied false identity details." (p.6)
 * Cooperation between ISPs and rights-holders

"This shows that as a last resort – the only effective way to curtail the damages caused by such persisting illegal websites is the blocking of access to the illegal site." (p.8)
 * Repression against further copyright infringements

Bsa (en)

 * bsa_en.pdf

"Rights holders must be able to process IP addresses, and service providers must be required to provide the true name and address of infringers to copyright owners in civil proceedings." (p.15)
 * Increased liability of ISPs

"Clarification that – consistent with EU law today – liability is not a condition for an injunction to issue against an online intermediary would be welcomed. Of course, such injunctions must be available only pursuant to a court order and after an opportunity to be heard. Injunctions against intermediaries also should not extend to the imposition of broad mandates for the use of technology filters screening all content or all users." (p.16)

"One option that the Commission may consider is a mechanism that would allow national courts, upon a case initiated by a public official, to order the termination of the operations by such sites by suspending their domain name registrations." (p.17)

[insert quote here]
 * Cooperation between ISPs and rights-holders

"Addressing this activity requires measures that (i) effectively deter illicit downloading, uploading, making available and use of content, and at the same time, (ii) ensure existing technologies function as designed, that innovation and the development of new technologies and services are not obstructed, and that users’ enjoyment of software, computers and the Internet is not 17 diminished. In adopting new measures to address internet piracy, due care must be taken to ensure policies meet both considerations." (p.16-17)
 * Repression against further copyright infringements

Bskyb (en)

 * bskyb_en.pdf

N/A
 * Increased liability of ISPs

N/A
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Businesseurope (en)

 * businesseurope_en.pdf

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.
 * Increased liability of ISPs

Closer cooperation between all authorities and actors involved including intermediaries is necessary.
 * Cooperation between ISPs and rights-holders

NO
 * Repression against further copyright infringements

Bwin Party (en)

 * bwin_party_en.pdf

N/A
 * Increased liability of ISPs

N/A
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Cable Europe (en)

 * cable_europe_en.pdf

"Imposing general monitoring or filtering obligations on ISPs via legal proceedings and changes in the IPRED could have the wrong consequences of raising legal uncertainty and disproportionate actions." (p.4)
 * Increased liability of ISPs

"Therefore, contrary to what the Commission’s Report on IPRED suggests, we would welcome additional implementation guidance from the Commission not through a modification to the IPRED, but through other non legislative means available. This should strengthen the liability limitations against tendencies of national courts (and demands from rights holders in particular) to establish or extend monitoring obligations for intermediaries." (p.4)

"Cooperation between stakeholders may be possible, however only within recognised framework, not beyond of it, and in the presence of consumer-friendly legal offers." (p.5)
 * Cooperation between ISPs and rights-holders

"article 8 is essentially used by right holders towards ISPs to obtain IP addresses and establish that the infringer has acted on a commercial scale or even, in some Member States, for all types of infringements. We certainly are not opposed to providing this kind of information when cable operators are in possession of the information being requested, and the request and disclosure of that information is being made in accordance with national privacy laws, including any court orders that are required." (p.2)

N/A
 * Repression against further copyright infringements

Cable Europe Ecta Etno Euroispa Gsma (en)

 * cable_europe_ecta_etno_euroispa_gsma_en.pdf

"The implementation of technical filters in ISPs’ networks and servers for communications generated by users, irrespective of whether they are alleged infringers or not, is contrary to the principles of the ECommerce Directive, providing that a general monitoring obligation cannot be imposed on ISPs in relation to the content transmitted over their operated networks. Moreover, such technical filters would be complex and very costly." (p.2)
 * Increased liability of ISPs

N/A N/A
 * Cooperation between ISPs and rights-holders
 * Repression against further copyright infringements

Ccia (en)

 * ccia_en.pdf
 * ccia_annex1_en.pdf

"Policymakers cannot retreat from the e-Commerce Directive’s prohibition on monitoring/filtering mandates. The scale of the Web today is unfathomable. With 35 hours of video added to YouTube every minute,5 Twitter users generating 150 million tweets per day,6 and Flickr hosting more than 5 billion images,7 the amount of information and expression shared by Internet users every day is without historical precedent. Online service providers are in no position to monitor and determine the legality of any given piece of content online. The imposition of responsibilities to monitor and filter services would inevitably be over-inclusive, sweeping in the transmission of non-infringing content. Filters cannot determine whether a particular transmission is permitted by limitations and exceptions. Moreover, a monitoring obligation may threaten user privacy, and would impede innovation as regulation and legislation move far more slowly than technology. Accordingly, the choice reflected in the e-Commerce Directive should be respected." (p.3)

Ccip (fr)

 * ccip_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ccip Fiche Synthese (fr)

 * ccip_fiche_synthese_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Cefic (en)

 * cefic_en.pdf

N/A
 * Increased liability of ISPs

N/A
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Ceipi (fr)

 * ceipi_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Cepi Fera Fiad Fiapf Ivf (en)

 * cepi_fera_fiad_fiapf_ivf_en.pdf

"As a general matter, online service providers whose services are directly (or even indirectly) “used in infringing activities” have an obligation to prevent such infringements"... (p.3) "As per the Enforcement, E-Commerce and Copyright Directives, such relief should available irrespective of the intermediary's liability for the underlying infringement. This is not about attributing liability to “intermediaries” but rather recognition of the fact that they are best placed to prevent the infringement or the continuation thereof." (p.3)
 * Increased liability of ISPs

N/A
 * Cooperation between ISPs and rights-holders

"We consider that it would be helpful to establish a general obligation on Member States to take legislative, administrative and other steps (for example facilitating voluntary agreements) to reduce all forms of IPR infringement on the Internet. Such steps should include measures related to prevention, inducement, and facilitation of mass forms of infringement. This includes dealing with source piracy as well. Given the nature of IPR infringements online, particularly with respect to copyright, Member States may need to adopt a range of measures to address Internet infringements and ensure that measures are not limited to addressing specific forms of infringement, e.g. unauthorized streaming." (p.3)
 * Repression against further copyright infringements

Chartered Institute Of Pa (en)

 * chartered_institute_of_pa_en.pdf

N/A
 * Increased liability of ISPs

N/A
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Cmba (en)

 * cmba_en.pdf

[insert quote here]
 * Increased liability of ISPs

"The information would however be available in the very moment where the infringing act is detected (assisted by available reliable technologies). In order to secure the information, right holders should have the possibility to request intermediaries to store the information (date, time and IP number), until the court order has been obtained (quick freeze). In the event that the court does grant the order to disclose, the data could then be erased by the intermediary at the end of the court procedure." (p.7)
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Cnac (fr)

 * cnac_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Colipa (en)

 * colipa_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Comite Colbert (fr)

 * comite_colbert_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Confindustria (it)

 * confindustria_it.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Confindustria Servizi Innovativi E Tecnologici (it)

 * confindustria_servizi_innovativi_e_tecnologici_it.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Constant (fr)

 * constant_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Consumer Focus (en)

 * consumer_focus_en.pdf

"We would oppose a wide interpretation of the provision on injunctions which would require ISPs to monitor content and prevent infringements in the future. This conflicts with the prohibition of general monitoring in the e-Commerce Directive. It would increase the operating costs of ISPs. These additional costs would be passed on to consumers and could reduce access to broadband, which is recognised as an essential service, for low income consumers." (p.3)
 * Increased liability of ISPs

"Under no circumstances should communication service providers be allowed or required to retain data and release such data to private agents or companies. The rights of citizens and consumers not to have their communication intercepted by private agents or companies without their consent should be safeguarded." (p.3)
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Dacs (en)

 * dacs_en.pdf

"Have a more refined and harmonised system included in the Enforcement Directive that puts rightsholders across Europe but also intermediaries like ISPs and infringers on a level playing field by stipulating the obligations of intermediaries towards rightsholders." (p.3)
 * Increased liability of ISPs
 * Cooperation between ISPs and rights-holders

"Introduce more effective and accessible legal remedies for visual artists, photographers and illustrators who feel increasingly powerless to challenge the unauthorised use, misuse and appropriation of their work due to the high costs of enforcement and the limited damages available." (p.3)
 * Repression against further copyright infringements

Danish Copyright Council (en)

 * danish_copyright_council_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Danish Patent Agents Association (en)

 * danish_patent_agents_association_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Danske Universiteter (dk)

 * danske_universiteter_dk.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Dbf (fr)

 * dbf_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Deutsche Patentanwaltskammer (de)

 * deutsche_patentanwaltskammer_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Deutsche Patentanwaltskammer Cover (de)

 * deutsche_patentanwaltskammer_cover_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Deutsche Post Dhl (en)

 * deutsche_post_dhl_en.pdf

N/A N/A N/A
 * Increased liability of ISPs
 * Cooperation between ISPs and rights-holders
 * Repression against further copyright infringements

Deutsche Telekom (en)

 * deutsche_telekom_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Deutscher Anwaltverein (de)

 * deutscher_anwaltverein_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Deutscher Markenverband (de)

 * deutscher_markenverband_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Dihk (de)

 * dihk_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Eaea (en)

 * eaea_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ebay (en)

 * ebay_en.pdf

N/A
 * Increased liability of ISPs

N/A
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Ebca (en)

 * ebca_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ebf Contribution (en)

 * ebf_contribution_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Eccia (en)

 * eccia_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ecta (en)

 * ecta_en.pdf

"It should absolutely be clarified that injunctions based on Articles 9 and 11 of the Directive are in no case affected by the limitations on ISP’s liability as set forth in the E-Commerce Directive and do not depend on the liability of the intermediary." (p.4)
 * Increased liability of ISPs

"Hence, even in a case where the ISP is “neutral” concerning the content transmitted or stored, it should be possible to obtain an injunction forcing the latter to remove the illegal content or block access to it." (p.4)

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Edima (en)

 * edima_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Edps (en)

 * edps_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Edri (en)

 * edri_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Efpia (en)

 * efpia_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Egdf (en)

 * egdf_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Egeda (en)

 * egeda_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Egma (en)

 * egma_en.pdf

N/A
 * Increased liability of ISPs

N/A
 * Cooperation between ISPs and rights-holders

N/A
 * Repression against further copyright infringements

Eli Lilly (en)

 * eli_lilly_en.pdf

... "Safe harbours" or legislative defences that protect intermediaries from liability if they remove their services from online pharmacies on good faith belief that such sites are advertising or selling counterfeit or illegal medicines. (p.1)
 * Increased liability of ISPs

... a Memorandum of Understanding should be developed to specifically encourage private sector companies that provide services to online pharmacies to: (i) share information on sites that sell counterfeit or illegal pharmaceuticals; (ii) take voluntary action to enforce their terms of service contracts and remove intermediary services from such rogue sites in order to protect the health and safety of EU consumers and prevent further IP infringements. ... (p.2)
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Emeca (en)

 * emeca_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Enpa50 (en)

 * enpa50_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Epa (en)

 * epa_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ericsson (en)

 * ericsson_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Esa (en)

 * esa_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Etno (en)

 * etno_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Eurocopya (en)

 * eurocopya_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Euroispa (en)

 * euroispa_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

European Fashion Council (en)

 * european_fashion_council_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

European Producers Club (fr)

 * european_producers_club_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

European Publishers Council (en)

 * european_publishers_council_en.pdf

[insert quote here]
 * Increased liability of ISPs

... collaboration with ISPs is part of the solution as well as cooperation with other intermediaries such as search engines, content aggregators and e-retailers. (p.3)
 * Cooperation between ISPs and rights-holders

... The law relating to the internet, unlike the offline world, requires proactive monitoring of the entire internet by content owners in order for infringements to be actionable... (p.1)
 * Repression against further copyright infringements

Faep (en)

 * faep_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Fast

 * fast.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Fastweb (en)

 * fastweb_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Fdn (fr)

 * fdn_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Fep (en)

 * fep_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Fesi (en)

 * fesi_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ffii (en)

 * ffii_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Finnish Commerce Federation (fi)

 * finnish_commerce_federation_fi.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Fimi (en)

 * fimi_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Fondation Giacometti (fr)

 * fondation_giacometti_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Fondation Hartung-bergman (fr)

 * fondation_hartung-bergman_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Fondation Le Corbusier (fr)

 * fondation_le_corbusier_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Fox International Channels (en)

 * fox_international_channels_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Fsfe (en)

 * fsfe_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Gema (de)

 * gema_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Gesac (en)

 * gesac_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Gi Dpi (es)

 * gi_dpi_es.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Giart (en)

 * giart_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Gleiss Lutz (en)

 * gleiss_lutz_en.pdf
 * gleiss_lutz_annex_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Google (en)

 * google_en.pdf

"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)

 * grupa_allegro_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Grur (de, en)

 * grur_de.pdf
 * grur_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Gsma europe (en)

 * gsma_ europe_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Hai Europe (en)

 * hai_europe_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Icc (en)

 * icc_en.pdf
 * icc_annex1_en.pdf
 * icc_annex2_en.pdf
 * icc_annex3_en.pdf
 * icc_annex4_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Icmp (en)

 * icmp_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ifpi (en)

 * ifpi_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ifrro (en)

 * ifrro_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Indicam (en)

 * indicam_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Inta (en)

 * inta_en.pdf
 * inta_annex_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Intel (en)

 * intel_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Internet Society (en)

 * internet_society_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Internet Society Poland Panoptykon (pl)

 * internet_society_poland_panoptykon_pl.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ip Federation (en)

 * ip_federation_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ipo (en)

 * ipo_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Isfe (en)

 * isfe_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ispa Austria (en)

 * ispa_austria_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ispa Belgium (en)

 * ispa_belgium_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Iuridicum Remedium (en)

 * iuridicum_remedium_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Johan Schl�ter Advokatfirma (dk, en)

 * johan_schl�ter_advokatfirma_en.pdf
 * johan_schl�ter_advokatfirma_annexe_dk.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Kepka (en)

 * kepka_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Kopiosto (fi)

 * kopiosto_fi.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ksb Sas (fr)

 * ksb_sas_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

La Quadrature Du Net (en)

 * la_quadrature_du_net_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

La-ex Fcforum (en)

 * la-ex_fcforum_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Les (en)

 * les_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Lesi (en)

 * lesi_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Lyhty (fi)

 * lyhty_fi.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Marques (en)

 * marques_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Medef (fr)

 * medef_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Mediaset (en)

 * mediaset_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Microsoft (en)

 * microsoft_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Mih (en)

 * mih_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Mpa (en)

 * mpa_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Nuovo Imaie (en)

 * nuovo_imaie_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Nurpa (en)

 * nurpa_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

ORG (en)

 * org_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Parti Pirate (fr)

 * parti_pirate_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Philips (en)

 * philips_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Pike (pl)

 * pike_pl.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Pin Sme (en)

 * pin_sme_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Pirelli (en)

 * pirelli_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ppl Uk (en)

 * ppl_uk_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Publishers Association (en)

 * publishers_association_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Qdlaty (en)

 * qdlaty_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Qxl Ricardo Denmark (en)

 * qxl_ricardo_denmark_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Qxl Ricardo Greece (en)

 * qxl_ricardo_greece_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Rga (en)

 * rga_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Rim (en)

 * rim_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Royal Tnt Post (en)

 * royal_tnt_post_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Royal Tnt Post Taxud (en)

 * royal_tnt_post_taxud_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Saa (en)

 * saa_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Sabam Form figures (en)

 * sabam_form_ figures_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Sabam Questionnaire (en)

 * sabam_questionnaire_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Sacd (fr)

 * sacd_fr.pdf

''« Il devrait donc être envisagé de préciser certaines dispositions de la directive 2004/48 pouvant être utilisées à leur encontre (aux intermédiaires techniques) afin de permettre l’application effective de ces dispositions dans toute l’Union européenne. De manière plus générale, il est essentiel de renforcer leurs obligations en matière de lutte contre la contrefaçon. »'' (II) « En ce qui concerne les mécanismes d’injonctions prévus à l’encontre des intermédiaires techniques, ils sont rendus inopérants dans différents Etats membres qui lient la possibilité d’y recourir à la reconnaissance de la responsabilité des intermédiaires techniques » (II, 1§5)
 * Increased liability of ISPs

''« La SACD considère qu’il est essentiel de prévoir dans la législation européenne des mesures de notification adaptées aux technologies dont disposent actuellement les intermédiaires techniques. »'' (II, 2§2)

« la procédure de « notification et retrait » pourrait être complétée par une obligation à la charge de l’intermédiaire technique d’éviter la mise à disposition de la même œuvre contrefaisante » (II, 2§3)

Summary : it is necessary to strengthen technical third parties' obligations in the field of the fight againt counterfeiting.

En faveur de la loi française « création et internet » (II, 1§4)
 * Cooperation between ISPs and rights-holders

Summary : SACD approves French law called "creation and Internet"

le cadre juridique existant est insuffisant pour lutter contre la contrefaçon numérique qui se développe à l’échelle européenne. (II)
 * Repression against further copyright infringements

Summary : the existing law is insufficient at the european level to fight against counterfeiting.

Sacg (en)

 * sacg_en.pdf

''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)
 * Increased liability of ISPs

''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)
 * Cooperation between ISPs and rights-holders

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)

''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)
 * Repression against further copyright infringements

''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)

 * sazas_si.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Sek (fi)

 * sek_fi.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Sroc (en)

 * sroc_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Stm (en)

 * stm_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Stop43 (en)

 * stop43_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Stowarzyszenie Portal Otwartej Informacji (pl)

 * stowarzyszenie_portal_otwartej_informacji_pl.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Sty (en)

 * sty_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Suomen Yritt�j�t (fi)

 * suomen_yritt�j�t_fi.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Swedish Publishers Association (en)

 * swedish_publishers_association_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Tacd (en)

 * tacd_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Tee (fr)

 * tee_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Telecom Italia (en)

 * telecom_italia_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Telefonica (en)

 * telefonica_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Teva (en)

 * teva_en.pdf
 * teva_annex1_en.pdf
 * teva_annex2_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Tie (en)

 * tie_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Tsic (en)

 * tsic_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ttvk Finnish Organisation (fi)

 * ttvk_finnish_organisation_fi.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Tuotos (fi)

 * tuotos_fi.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Uk Music (en)

 * uk_music_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Unifab (fr)

 * unifab_fr.pdf
 * unifab_annexe1_fr.pdf
 * unifab_annexe2_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Union (en)

 * union_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Upu (en, fr)

 * upu_en.pdf
 * upu_fr.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Vdma (de)

 * vdma_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Ver.di (de)

 * ver.di_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Vit Hnilica (cz)

 * vit_hnilica_cz.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Vno Ncw Mkb Nederland (en)

 * vno_ncw_mkb_nederland_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Voez (en)

 * voez_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Vprt (de)

 * vprt_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Vrijschrift (en)

 * vrijschrift_en.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements

Vzbv (de)

 * vzbv_de.pdf

[insert quote here]
 * Increased liability of ISPs

[insert quote here]
 * Cooperation between ISPs and rights-holders

[insert quote here]
 * Repression against further copyright infringements