Preliminary submissions on European Commission staff ... · Source language: English CISAC DOCUMENT 1/13 28/07/2005 ... CISAC is convinced of the Commission’s bona fide ... in another

SG05-0726 Source language: English

CISAC DOCUMENT

1/13

28/07/2005

Preliminary submissions on European Commission staff working document “Study on a community initiative on the

cross-border collective management of copyright”

Preliminary submissions on European Commission staff working document “Study on a community initiative on the cross-border collective management of copyright”

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1 - Introduction to CISAC

1. Founded in 1926, CISAC is a non-governmental, non-profit organisation with headquarters in Paris and with regional offices in Buenos Aires, Budapest and Singapore. CISAC has a membership of 210 authors’ societies (“Societies”) in 109 countries, a very substantial number of these Societies operating without of the European Union (“Union” or “Europe”).

2. CISAC indirectly represents more than 2 million creators (namely authors, composers

and publishers), and covers all the creative repertoires. Thus the CISAC world embraces music, drama, literature, audio-visual media, graphic arts and visual arts. A list of CISAC’s members appear as an annex to these submissions.

3. The total amount of royalties collected by CISAC’s member societies in 2003 was

almost 6.7 billion Euros, a 5.8% increase over 2001. Income from copyright musical works and associated lyrics (“Musical Works”) currently represents well over 90% of those royalties.

4. CISAC’s main objectives are, inter alia, to:

i. promote the establishment as well as the development of Societies; and ii. watch over, safeguard and contribute to the legal interests of creators, both in

the international sphere and in the domain of national legislation, especially in relation to authors' rights.

2 - Reasons for, and limits to, these submissions

1. These submissions are made within the context of CISAC’s objectives, as set out in the immediately preceding paragraph. CISAC is making these submissions for the following five reasons:

i. The challenges posed by the new technologies do not recognise the

European frontiers. Non-European copyright works are exploited in Europe, whilst European copyright works are exploited outside of Europe. Moreover, what happens in the Union may, one way or another, have a profound impact on non-European business models. It follows from this that the Union cannot find a solution in isolation. Dialogue with the outside world – including dialogue with non-European Societies – is essential. CISAC stands ready to assist in whatever way it can to facilitate such dialogue and makes these preliminary submissions as an introductory step in this discussion process.

ii. The challenges posed by the new technologies concern not just Musical

Works but almost all forms of artistic expression such as audiovisual works, literary works and visual works. CISAC, as an international representative of all creative fields believes that action from the limited perspective of Musical Works without due regard to other forms of exploitation will have a deleterious ripple effect on non-Musical Works. Before any action is taken in this area, the impact of such action on non-Musical Works must be assessed.


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iii. The document, “Study on a Community Initiative on the cross-border collective management of copyright” dated 7 July 2005 (“Document”) and produced by the European Commission (“Commission”) refers to various Articles in the CISAC model reciprocal contract (“Model Contract”). It is primarily CISAC’s responsibility to clarify any possibly erroneous interpretations of the Model Contract’s provisions.

iv. CISAC is currently involved with the other music industry organisations in

discussions aimed at facilitating the on-line licensing of Musical Works through globally uniform asset identification and sales reporting standards1. Any action in the cross-border management of copyright must take into account these technical and practical discussions.

v. As CISAC is a party to the Music Choice Europe and RTL case which

expressly concerns cross-border collective management of copyright, it is important for CISAC to be involved in any discussions which might have a bearing thereon.

2. These submissions have the following two limits:

i. It is not the aim of these preliminary submissions to deal in a comprehensive

manner with all the issues contained in the Document. As the Document raises fundamental European matters, primary responsibility for responding to the Commission on behalf of European Societies is quite properly being discharged by CISAC’s sister organisation, GESAC. Accordingly the fact that these submissions do not comment on any particular aspect of the Document should not be interpreted as acceptance by CISAC of that aspect. CISAC is relying on GESAC to produce a comprehensive response to the Commission and fully supports the said response. Rather it is the aim of these submissions to deal only with one or two issues which directly concern CISAC’s international field of activity.

ii. It is not the aim of these preliminary submissions to provide concrete

solutions for the future. The inordinately short three-week July deadline imposed by the Commission simply does not permit CISAC’s 200 plus members to provide proposals in this regard. CISAC unreservedly accepts that the most important part of the current process is to construct a long-lasting regime for the cross border management of copyright in the online world. However, this process must be measured and must avoid a rush to judgement. After all, the consultation process must allow all interested parties – and not just Societies – constructively to review a system which has taken well over a century to perfect. Accordingly CISAC is in contact with its 200 plus members and shall be making subsequent submissions on its concrete proposals for the future. CISAC is convinced of the Commission’s bona fide desire to allow due consultation and trusts that the Commission will take CISAC’s subsequent submissions into account.

1 The “Music Industry Integrated Identifier Project” (“MI3P”), with IFPI and RIAA as well as BIEM.


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3 - Facts and statements that may need clarification

1. CISAC must respectfully point out that the Document contains several facts and statements that may need clarification on CISAC’s part, including, but not limited to, the following four points:

i. Exclusivity Paragraph 1.1.4.1 of the Document contains the statement “[t]herefore the licensee CRM obtains the right to license the entire repertoire of the licensor CRM on an exclusive basis in its territory”. This statement does not follow logically at all from the argumentation in the current version of the Document. Simply because there are territorial limits in a contract between two Societies does not mean that such contract is exclusive (as Paragraph 1.1.4.1 of the Document concludes). Such contract could equally be non-exclusive. Indeed, as the Commission well knows, the Model Contract has provided for non-exclusivity between European Societies since 1996 (resolution N° CJL/96/1159 of the CISAC Legal Committee, endorsed by the General Assembly in 1996 during its Paris meeting), a policy reaffirmed by the CISAC Executive Bureau in October 2003. CISAC therefore wonders whether one step has perhaps been omitted in the Commission’s line of argument.

ii. Nationality restrictions Paragraph 1.1.4.3 of the Document refers to Article 11 (II) of the Model Contract. As the Commission will no doubt recall, CISAC has removed this provision from its Model Contract.

iii. Statistical comparators Paragraphs 1.4.2 and 1.4.3 of the Document contain several statistics on what the Document calls “non-domestic” collections. The effect of these paragraphs is to suggest that there exist discrepancies between non-domestic collections and non-domestic distributions that are difficult to explain. CISAC feels the need to comment on these negatively charged paragraphs. The clear implication is that European Societies are not distributing equitably. The clear implication is also that both European and non-European Societies are failing in their stewardship duties towards their members – namely to ensure that those members receive the royalties which are due to them in respect of non-domestic collections.

In response to the Commission’s assertions, we would respectfully point out that the Commission’s arguments do not appear to give due regard to the following critical factors:


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a. Publishing contracts between composers and publishers often grant to

publishers up to 50% of performing right royalties (“Royalties”) due in respect of the exploitation of a Musical Work. Such grant of the right to receive Royalties often operates on a worldwide basis. By way of illustration, an Australian composer may grant to his publisher the worldwide right to receive 50 Euros for every 100 Euros to which that Australian composer is entitled in respect of the composer’s so-called Australian Musical Work when performed in another country. Thus, when that so-called Australian Musical Work is exploited in France, the Australian composer receives his share from the Australian society APRA via the French society while the 50 Euro publisher share may be distributed to the publisher’s French sub-publisher. This French sub-publisher may be a member of French Society SACEM and may well be contractually obliged to assist in the exploitation of the so-called Australian Musical Work in the French territory. Accordingly, using the statistical analysis adopted in the Document, only 50 Euros will be shown as having been distributed in respect of an Australian Musical Work. For its part, under the Document’s statistical approach, SACEM will have been deemed to have made a 50 Euro domestic distribution – even though the Musical Work was in fact “Australian”. Whilst the Document briefly alludes to this issue, the Document then appears to give little or no weight to such a critical factor in its subsequent argumentation.

b. Many successful composers of one country are already direct members of

Societies situated in another country (a fact, incidentally which appears to have been overlooked when formulating the discrimination arguments contained in paragraphs 1.1.4.3 of the Document). By the very reason of his success, a popular Turkish composer will generate substantial royalties in respect of his so-called Turkish Musical Works. Yet these substantial royalties will (following the Document’s logic) be identified within GEMA’s domestic distributions if that Turkish composer has chosen (as he is perfectly entitled to do under current arrangements) to be a direct member of GEMA. In short, it is precisely because Societies do not discriminate and it is exactly because Societies do accept non-nationals as members that confusing figures such as those contained in the Document are generated.

c. Distributions cannot precisely mirror music usage since allowances must be

made for administration expenses as well as social and cultural funds before distribution. If a Society has collected 60 Euros in respect of domestic Musical Works, this does not mean that it has distributed 60 Euros to its own members. That Society must cover its administration expenses before distribution. Naturally, non-domestic distributions will also be reduced by a proportionate share of the deductions. In short, the Document appears to distort the proportionality between non-domestic and domestic distributions.

d. Markets such as France, Germany and Spain have extremely successful local

repertoires. It is therefore not surprising that in such territories, non-domestic collections are significantly lower than domestic collections.


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iv. Business comparators

Paragraph 1.1 of the Document effectively argues that the current national performing right blanket licence (“Blanket Licence”) bears a responsibility for the alleged failure of European industry to match its American counterpart. CISAC wonders whether this argument has been fully developed and would be grateful for access to all the concrete empirical evidence which the Commission will without doubt have acquired before coming to this far-reaching conclusion. After all, were it not for such evidence, commonsense would otherwise dictate that additional factors would be at least equally important.

By way of example only, CISAC cannot over-emphasise the importance of the divergent state of technological development of the European versus US on-line infrastructure. In the US, the hard-wired computer is the medium of choice to access “on-line” digital content and services. In Europe, this is mainly done wirelessly via more advanced interoperable and ubiquitous mobile phones. In order to be relevant, any comparison of the state of the legitimate on-line business on both sides of the Atlantic must therefore encompass and consolidate both markets. Such an approach will result in a picture which is far less superficial and more balanced than the Document would at first indicate.

Other critical factors equally have their role to play. Fiscal regimes, economic development, financial resources and serendipity must all be taken into account. Even regulatory provisions and competition authorities would surely also be influential on the development of the on-line industries. If the problem were as simple as collective management territoriality, then huge single markets such as China and India would have a far more developed on-line market than that of the United States of America.

Indeed, CISAC would go even further than this and argue that it is precisely because of the well-established Blanket Licence system which has stood the test of time that there is today a level playing field for innovators. Since CISAC’s members apply the same system in the hundred or more territories in which those members are situated, an equal opportunity has been offered to the entrepreneur, whether he be from Sweden or from Burkina Faso. After all, a Blanket Licence covering the Russian Federation is near identical to a Blanket Licence offered in St Lucia, thanks to the network of reciprocal representation contracts with which the Commission is familiar. In the premises, CISAC believes that it would preferable to set aside syllogistic comparators and to concentrate rather on the central issue, namely on how to provide an effective cross-border collective management system in an on-line environment. n short, the blanket license system first used by CISAC societies has provided access to a world-wide repertoire for over 150 years and this system makes even more sense today when access is expected to be on-line, instantaneous and available from any territory.


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4 - The way forward

1. Traditionally the world has been divided by linguistic, cultural, economic, social, national, regional, continental, political and legal differences. The collective administration system did not create those differences – differences which are still very much evident today - but rather reflected them. With recent technological advances, the world has, perhaps for the first time, an element for which there are no boundaries. CISAC fully recognises – embraces – this reality and equally accepts that the collective management system must reflect the new order.

2. CISAC acknowledges that in view of the issues raised by the Document, the

collective management system should be reviewed in order to ensure that it responds optimally to a changed technological world. Furthermore, as it has shown with its numerous standardisation and digital initiatives (such as CIS, ISWC, ISAN, IPI and MI3P), CISAC welcomes the new technologies but simply believes that those technologies should be put within the context of a properly regulated framework. As discussed above, CISAC is in contact with its members with a view to making concrete proposals on what exactly constitutes “a properly regulated framework” and shall be making subsequent submissions in this regard. However, even before the termination of this discussion process, at least six facts are clear:

i. Balance

Any future framework must maintain an equitable balance between copyright users (many of whom are increasingly powerful multi-national conglomerates with centres of business and financial interests without of the Union) on the one hand, and creators (many of whom are situated within the Union and depend on their national Society for their very survival) on the other hand.

ii. Copyright infringement

A future structure needs to take into account, not just how a Society will deal with a copyright user who wishes to take out a pan-European licence, but also with a copyright user who does not. It is all very well a Swedish composer requesting a Maltese Society to issue a pan-European licence on her/his behalf to a law-abiding Mandarin-speaking copyright user with its registered office in the Bahamas and with its main economic interests in Ireland. That is the easiest (though by no means easy) part. However, the system also needs to work out how the Maltese Society will deal with a Chilean copyright user based in Luxembourg who refuses to honour its copyright obligations. If the Maltese Society is not able to do so, the user based in Luxembourg will have a discriminatory advantage over the user’s Irish counterpart. The Irish copyright user will without doubt soon equally refuse to honour its copyright obligations, thereby undermining the Union’s copyright regime.


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iii. Duplication

Any future model must avoid duplication – or indeed triplication. In the example contained within the immediately preceding paragraph, if the copyright user based in Luxembourg is infringing the Maltese Society’s repertoire, the chances are that it will also be infringing the Danish and Austrian Society’s repertoire. If care is not taken, the multiple legal and other fees of every copyright society which has repertoire to administer in Luxembourg will decrease – and may well subsume - the royalties payable to the creative community. Even negotiations with willing copyright users have financial and administrative implications, the impact of which must be fully assessed before an appropriate future system can emerge.

iv. National and regional differences

Any future system must recognise that national and regional differences continue to play an important role today and will continue to play an important role tomorrow. European single market legislation generated by the Union has done little to alter these differences – even copyright legislation remains essentially national in origin.

The promotion of natural and regional cultural heritages has never been more pronounced. Thus, at a time when the Union’s constituent states are publicly committing themselves to cultural diversity, it would be particularly paradoxical if the Commission were advocating a policy which would have the opposite effect. In particular any policy which would encourage users to cherry pick a few safe (often non-European) successful creators would appear to run contrary to the Union’s current policy on cultural diversity. v. International relations

The true value of collective administration to an on-line copyright user lies, not in a pan-European licence, but rather in a global licence. All interested parties can discuss cross border collective management of copyright – and indeed, it is desirable that they should do so. However, the simple truth is that the new technologies are no respecter of the boundaries of the Union. Any Union approach is meaningless if it is inconsistent with approaches being adopted elsewhere or if it does not facilitate trade with countries outside the Union. If the future European model is to have any value to anybody, it needs to include workable plans on exactly how an American Musical Work will be administered in the Union and how a Portuguese audiovisual copyright work will be administered in Brazil.


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vi. the Blanket Licence system

A significant part of the Document is dedicated to challenging the contracts of reciprocal representation between European Societies which are based on the Model Contract. Consciously or otherwise, this must inevitably call into question the comprehensive Blanket Licence system which lies at the root of those contracts. CISAC believes that the Commission’s questioning approach is healthy. After all, it is not simply because something has proved successful for the best part of a century that it should continue in the future. Nevertheless, CISAC maintains that the current comprehensive Blanket Licence system continues to represent the optimum and indispensable licensing method for creator, user and society as a whole. CISAC would go even further than this and would contend that nowhere is the current comprehensive Blanket Licence more necessary than in the on-line environment.

From the point of view of the creator, the Blanket Licence benefits her/him in at least two ways:

a. The Blanket Licence system means that no individual has to attempt the

impossible task of dealing with the large number of persons and organisations that might wish to exploit her/his copyright work. Nowhere is this task more difficult than in the on-line world since, with the birth of the internet, the potential for the exploitation of a copyright work has been greatly increased.

b. In these days of increasingly powerful (often non-European) copyright users,

the Blanket Licence system provides collective bargaining power which affords a creator some chance of negotiating equitably with the users of his works. Bearing in mind the fact that the on-line market will probably be dominated by large players, the solidarity principle underpinning the Blanket Licence would appear more relevant than ever before.

From the point of view of the copyright user, societies benefit him in at least two ways:

a. The copyright user does not have to keep coming back to the individual

creator to ask for specific licences in respect of specific works. It may not, for example, know which works are to be exploited nor may it even know the composers of the works.

b. If the copyright user takes a Blanket Licence from a Society, the likelihood of it infringing copyright by the exploitation any particular work is virtually nil. This is because, thanks to the Blanket Licence system, Societies can grant a licence that is valid for a very substantial portion of all Musical Works. The comprehensive Blanket Licence gives the user complete peace of mind that whatever copyright work it uses will almost certainly be licensable by the Society and that the Society will never refuse to grant a licence in respect of specific copyright works. The whole of the worldwide repertoire of Musical Works is therefore open to any user of those works. In short, one of the strengths of on-line forms of exploitation is that it offers the music user the opportunity to make available any work to any individual at any moment situated in any part of the world. If the first part of this equation is removed – in other words if the user is not able to offer any work but rather a limited number of such works, then its business model, is much less valuable.


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From the point of view of Society as a whole, the Blanket Licence is also extremely beneficial. One catastrophic side-effect of the absence of a Blanket Licence system, as outlined above, may well be that a user, deprived of the opportunity of an extensive repertoire, will simply rely on a more limited list of popular (more often than not, incidentally, non-European) works. Such usage will be to the exclusion of, a deeper, richer catalogue consisting of works that may not necessarily have ever been performed in great numbers but that are nonetheless the unique expressions of creators from diverse countries. How much poorer the world’s culture will be for that.

In the light of the above, CISAC believes that, in forging a way forward, any future model must have at its centre the maintenance of a comprehensive Blanket Licence system, albeit a system adapted to the on-line world.

5 - Conclusions

1. CISAC has read with interest the Commission’s proposals contained within the Document and believes that (provided safeguards are carefully instilled in the system to protect creator and user alike), many – though by no means all - of those goals as outlined in these proposals are worth endorsing. CISAC also believes that a great number of Commission’s proposals are feasible in the short and medium term.

2. The main purpose of these submissions is not to highlight the inherent problems of

the Document (the breath taking speed at which the Document was produced made such problems inevitable), but rather to emphasise the need for all parties to join together in finding a long-lasting and permanent solution. After all, any system must have a degree of buy-in from the interested parties if ideas which look good on the drawing board are to work in practice.

3. CISAC makes these submissions in a constructive spirit and is quite sure that the

Commission will receive them in the way in which the submissions were intended. Accordingly, CISAC remains ready, willing and able to liaise with the Commission and with other interested parties on the next and more important stage – namely in constructing a workable and durable model for the future.

________________

SOCIETY MEMBERSHIP COUNTRYAACIMH Provisional Member HONDURASABRAMUS Ordinary Member BRAZILACAM Ordinary Member COSTA RICAACCESS Provisional Member CANADAACDAM Ordinary Member CUBAACUM Ordinary Member ISRAELADAGP Ordinary Member FRANCEADAVIS Provisional Member CUBAADDAF Provisional Member BRAZILAEPI Ordinary Member GREECEAGADU Ordinary Member URUGUAYAGAYC Associated Member GUATEMALAAKKA-LAA Ordinary Member LATVIAAKM Ordinary Member AUSTRIAALBAUTOR Ordinary Member ALBANIAALCS Associated Member UNITED

KINGDOMAMAR Ordinary Member BRAZILAMCOS Associated Member AUSTRALIAAMRA Provisional Member UNITED

STATESAPA Ordinary Member PARAGUAYAPDAYC Ordinary Member PERUAPG-Japan Associated Member JAPANAPRA Ordinary Member AUSTRALIAAPSAV Provisional Member PERUARGENTORES Ordinary Member ARGENTINAARMAUTHOR Ordinary Member ARMENIAARS Ordinary Member UNITED

STATESARTEGESTION Provisional Member ECUADORARTISJUS Ordinary Member HUNGARYASCAP Ordinary Member UNITED

STATESASSIM Provisional Member BRAZILATN Ordinary Member CHILEAUSTRO-MECHANA

Ordinary Member AUSTRIA

AUTORARTE Ordinary Member VENEZUELAAUTVIS Provisional Member BRAZILAWGACS Provisional Member AUSTRALIAAsDAC Provisional Member MOLDOVA,

REPUBLIC OFBBDA Ordinary Member BURKINA

FASOBCDA Ordinary Member CONGO

BEELDRECHT Ordinary Member NETHERLANDSBELAT Ordinary Member BELARUSBGDA Ordinary Member GUINEABILD-KUNST Ordinary Member GERMANYBMDA Ordinary Member MOROCCOBMI Ordinary Member UNITED

STATESBNDA Ordinary Member NIGERBONO Ordinary Member NORWAYBSDA Ordinary Member SENEGALBUBEDRA Ordinary Member BENINBUCADA Associated Member CENTRAL

AFRICANREPUBLIC

BUMA Ordinary Member NETHERLANDSBUMDA Ordinary Member MALIBURAFO Ordinary Member NETHERLANDSBURIDA Ordinary Member COTE D’IVOIREBUS Ordinary Member SWEDENBUTODRA Ordinary Member TOGOCASH Ordinary Member HONG KONGCCL Associated Member TRINIDAD AND

TOBAGOCHA Ordinary Member TAIWAN,

CHINESE TAIPEICMRRA Associated Member CANADACOMPASS Ordinary Member SINGAPORECOPY-DAN BILLEDKUNST

Ordinary Member DENMARK

COSCAP Ordinary Member BARBADOSCOSGA Associated Member GHANACOSOMA Associated Member MALAWICOSOTA Provisional Member TANZANIA,

UNITED REPUBLIC OF

COTT Ordinary Member TRINIDAD AND TOBAGO

CPSN Associated Member NEPALCREAIMAGEN Ordinary Member CHILECSCS Provisional Member CANADACopyRo Associated Member ROMANIADACS Ordinary Member UNITED

KINGDOMDALRO Ordinary Member SOUTH

AFRICADGA Associated Member UNITED

STATES

Premiminary submissions on European Commisssion staff working document“Study on a community initiative on the cross-border collective management of copyright”

LIST OF CISAC Members

Annex

CISAC Document 11/13

DILIA Ordinary Member CZECH REPUBLIC

DIRECTORES Ordinary Member MEXICODPRS Ordinary Member UNITED

KINGDOMDRCC Provisional Member CANADAEAU Ordinary Member ESTONIAFILM JUS Ordinary Member HUNGARYFILMAUTOR Ordinary Member BULGARIAFILSCAP Associated Member PHILIPPINESGEMA Ordinary Member GERMANYGESAC Associated Member BELGIUMGESTOR Provisional Member CZECH

REPUBLICHAA Ordinary Member CROATIAHDS-ZAMP Ordinary Member CROATIAHMS Associated Member SAINT LUCIAHUNGART Ordinary Member HUNGARYIMRO Ordinary Member IRELANDIPRS Ordinary Member INDIAJACAP Associated Member JAMAICAJASRAC Ordinary Member JAPANKCI Ordinary Member INDONESIAKODA Ordinary Member DENMARKKOMCA Ordinary Member KOREA,

REPUBLIC OFKOPIOSTO Associated Member FINLANDKOSA Associated Member KOREA,

REPUBLIC OFKUVASTO Ordinary Member FINLANDKazAK Associated Member KAZAKSTANKyrgyzpatent Ordinary Member KYRGYZSTANLATGA-A Ordinary Member LITHUANIALATINAUTOR Associated Member URUGUAYLIRA Ordinary Member NETHERLANDSLITA Ordinary Member SLOVAKIALITERAR-MECHANA

Ordinary Member AUSTRIA

LVG Ordinary Member AUSTRIAMACP Ordinary Member MALAYSIAMASA Ordinary Member MAURITIUSMCPS Ordinary Member UNITED

KINGDOMMCSC Ordinary Member CHINAMCSK Ordinary Member KENYAMCSN Ordinary Member NIGERIAMCT Associated Member THAILANDMESAM Ordinary Member TURKEYMSG Ordinary Member TURKEY

MUSICAUTOR Ordinary Member BULGARIAMUSIKEDITION Associated Member AUSTRIAMÜST Ordinary Member TAIWAN,

CHINESE TAIPEINASCAM Ordinary Member NAMIBIANCB Ordinary Member DENMARKNMPA Associated Member UNITED

STATESOMDA Associated Member MADAGASCARONDA Ordinary Member ALGERIAOSA Ordinary Member CZECH

REPUBLICOTPDA Ordinary Member TUNISIAPAPPRI Associated Member INDONESIAPROLITTERIS Ordinary Member SWITZERLANDPRS Ordinary Member UNITED

KINGDOMRAO Ordinary Member RUSSIAN

FEDERATIONSABAM Ordinary Member BELGIUMSACD Ordinary Member FRANCESACEM Ordinary Member FRANCESACEM-LUXEMBOURG

Provisional Member LUXEMBOURG

SACERAU Ordinary Member EGYPTSACK Ordinary Member KOREA,

REPUBLIC OFSACM Ordinary Member MEXICOSACVEN Ordinary Member VENEZUELASADAIC Ordinary Member ARGENTINASADEMBRA Ordinary Member BRAZILSADH Ordinary Member GREECESAMRO Ordinary Member SOUTH

AFRICASARRAL Ordinary Member SOUTH

AFRICASARTEC Ordinary Member CANADASAS Ordinary Member GEORGIASAYCE Ordinary Member ECUADORSAYCO Ordinary Member COLOMBIASAZAS Ordinary Member SLOVENIASBACEM Ordinary Member BRAZILSBAT Ordinary Member BRAZILSCAM Ordinary Member FRANCESCD Ordinary Member CHILESESAC Inc. Ordinary Member UNITED

STATESSESAM Associated Member FRANCESGA Provisional Member GUINEA

BISSAU



SGACEDOM Provisional Member DOMINICANREPUBLIC

SGAE Ordinary Member SPAINSGDL Associated Member FRANCESIAE Ordinary Member ITALYSICAM Ordinary Member BRAZILSNAC Associated Member FRANCESOBODAYCOM Associated Member BOLIVIASOCAN Ordinary Member CANADASOCINPRO Ordinary Member BRAZILSODART Associated Member CANADASODRAC Ordinary Member CANADASOFAM Ordinary Member BELGIUMSOGEM Ordinary Member MEXICOSOKOJ Ordinary Member YUGOSLAVIASOMAAP Ordinary Member MEXICOSOMAS Provisional Member MOZAMBIQUESONECA Ordinary Member CONGO, THE

DEMOCRATIC REPUBLIC OF THE

SOPE Associated Member GREECESOZA Ordinary Member SLOVAKIASPA Ordinary Member PORTUGALSPAC Ordinary Member PANAMASPACEM Ordinary Member FRENCH

POLYNESIASPACQ Associated Member CANADASQN Ordinary Member BOSNIA AND

HERZEGOVINASSA Ordinary Member SWITZERLANDSTEF Ordinary Member ICELANDSTEMRA Ordinary Member NETHERLANDSSTIM Ordinary Member SWEDENSUISA Ordinary Member SWITZERLANDSUISSIMAGE Associated Member SWITZERLANDSuomenKirjailijaliitto

Associated Member FINLAND

TALI Provisional Member ISRAELTEATERAUTOR Provisional Member BULGARIATEOSTO Ordinary Member FINLANDTONO Ordinary Member NORWAYThe Author’sRegistry Inc.

Associated Member UNITEDSTATES

UACRR Provisional Member UKRAINEUBC Ordinary Member BRAZILUCMR-ADA Ordinary Member ROMANIAUCOSO Provisional Member UGANDA

UFFICIOLEGALE

Associated Member HOLY SEE (VATICAN CITY STATE)

VAGA Ordinary Member UNITEDSTATES

VBK Ordinary Member AUSTRIAVDFS Associated Member AUSTRIAVEGAP Ordinary Member SPAINVEVAM Ordinary Member NETHERLANDSVI$COPY Ordinary Member AUSTRALIAWGA Associated Member UNITED

STATESWGJ Ordinary Member JAPANZAIKS Ordinary Member POLANDZAMCOPS Ordinary Member ZAMBIAZAMPMacedonia

Associated Member MACEDONIA, THE FORMER YUGOSLAVREPUBLIC OF

ZAMP Association of Slovenia

Provisional Member SLOVENIA

ZAPA Associated Member POLANDZIMRA Ordinary Member ZIMBABWE



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Preliminary submissions on European Commission staff ... · Source language: English CISAC DOCUMENT 1/13 28/07/2005 ... CISAC is convinced of the Commission’s bona fide ... in another