Michael Geist: Government May Be Altering Copyright Submissions…

Michael Geist: Government May Be Altering Copyright Submissions Without Consent

The copyright consultation has one of its biggest days today with a major town hall in Toronto, a roundtable hours before, and increased media coverage. The consultation has attracted growing attention in recent weeks as the chart on submissions below demonstrates. There are now over 3,000 submissions with the overwhelming majority of them speaking out against Bill C-61, anti-circumvention rules, and for stronger fair dealing (earlier charts here, here, and here).

Unfortunately, the chart is not entirely accurate in part because the government has effectively been altering some of the submissions. This issue has arisen because of the large number of Canadians that have chosen to use the CCER submission form service. The service allows anyone to submit their comments by either using a form letter or modifying the content as they see fit. The government has decided to treat virtually all submissions from the CCER IP address as the form letter and simply added the relevant name to a single copy of the letter (the chart below reflects the fact that each letter is, in fact, an individual submission. Note that this is not limited to CCER, the government is doing the same thing for a form letter from the Canadian Private Copying Collective). I am reliably told that 10 to 20 percent of people who use the CCER site modify their submissions. The government’s approach has wiped out those modifications entirely by adding names to a letter that they did not sign.