- From: Edward Hasbrouck <ehasbrouck@nwu.org>
- Date: Thu, 03 Aug 2023 10:11:27 -0700
- To: "public-tdmrep@w3.org" <public-tdmrep@w3.org>
On 3 Aug 2023 at 12:15, "Laurent Le Meur" <Laurent Le Meur <laurent@edrlab.org>> wrote: > What is sure is that I'd like to see something written by the EU > Commission itself about the geographical scope of their work. This is a point on which we can agree. On behalf of the National Writers Union (USA) and the International Federation of Journalists, and as a member of the board of the International Federation of Reproduction Rights Organizations, I was part of meetings with staff of the European Commission, as well as with MEPs and their staff, throughout the consideration of the CDSM Directive. We found them, in general, focused on the laws of the EU and its member states, and very reluctant to consider wider international implications of EU law and practice or worldwide treaties such as the Berne Convention. (To be fair, US officials are even less interested in international law.) Of course this is problematic. Impacts outside the EU of activities in the EU are inevitable. For example, my Web site is hosted and first published in Canada but proxied by Cloudflare (as is a large percentage of all Web traffic worldwide), a US entity with proxy servers in countries around the world. If a bot running on a server in Germany retrieves a page of my site from a Cloudflare proxy server in Germany, is this subject only to German and EU law? Or also to Canadian (and/or US) law? Certainly the Berne Convention is implicated: Germany and Canada are both parties to the Berne Convention, so the treaty sets minimum requirements for the protection which Germany must provide to works first published in Canada. Could the bot detect that the root server from which Cloudflare retrieves the file is in Canada? Possibly not in any currently standardized way, although it is stated in text in the HTML headers. We have continued to seek clarification since the Directive was enacted, but the EC has been reluctant to acknowledge these complications. Before issuing the joint public statement I shared with this group, creators contacted the EC and the EU Intellectual Property Office seeking clarification of the scope of the exceptions in Articles 3 and 4. We were disappointed that they provided no clarification whatsoever. The joint statements from creator organizations followed. One of their explicit goals is to prompt the EU to clarify the scope of the exceptions in Articles 3 and 4 as they apply to generative AI -- whether through legislation, regulations, or authoritative interpretive guidance. Creators would welcome the support of participants in this group in that effort. Sincerely, Edward Hasbrouck ---------------- Edward Hasbrouck <ehasbrouck@nwu.org> +1-415-824-0214 (San Francisco) National Writers Union https://nwu.org +1-212-254-0279 (New York)
Received on Thursday, 3 August 2023 17:11:35 UTC