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by dannyobrien 2758 days ago
Hi, I'm Danny O'Brien -- I work at EFF on Article 13.

So we talk a little a bit about this earlier this week: https://www.eff.org/deeplinks/2018/11/yes-eus-new-copyrightd...

I've mentioned this in Hacker News threads before, but here are the few things to bare in mind.

Firstly, the SME exemption (as well as the specific exceptions for Wikipedia and Github) was put in at the last moment in an attempt to win enough votes to get the Directive through the plenary following widespread opposition. It only exists in the European Parliament text, which is currently being negotiated with the original Council text. The news from the trilogues is that there's lots of lobbying to get it removed.

The exemptions sound good for Github and Wikipedia on paper: but Github and Wikipedia are the services that currently exist, and have been effectively grandparented in. It doesn't speak for all the other potential services that we can't describe, because they don't exist yet -- and won't exist if there's a liability regime that would have stopped Github and Wikipedia in their tracks if it had written before.

Thirdly, we know from experience that these exemptions don't work. In the European Parliament text, we have a blanket liability regime, which means that rightsholders can sue you, or your provider, by default. You can argue back, "oh it's okay, we're covered by this exemption", but you have to prove that you're really covered by the exemption -- and the expression of that exemption in each of the 28 implementations of the Directive in the member states. It creates a default of liability, and then fences of a small section of the Internet where you may be protected.

In the mean time, you -- as a person who hasn't paid up for a licensing arrangement with the major rightsholders -- will be on the receiving end of repeated orders to take down content, with the understanding if you don't successfully argue against that exemption, or the moment you cross that SME line, you'll be liable to an unbounded extent.

Why would you take that risk? How could you protect yourself against that risk?

Also note that many of these exemptions are expressed in the Recitals, which merely indicate the spirit of the law, the specific rules for transposition in the Articles themselves. Generally speaking, if you are threat-modelling new law, you might as well ignore the Recitals, because there is a substantial lobbying and legal community who have a big financial incentive to guide lawmakers, and deploy lawsuits in such a way as to sideline those non-binding commitments.

The exemption language was an attempt by lawmakers taken aback by the force of the opposition to Article 13 and 11, to both win over votes in the Parliament, and stop GitHub, Wikimedia and its users from complaining. The reason why Github, and Wikimedia and their users continue to complain is that they don't believe they can act in the future as though these exemptions will really work for them — and they have an interest in maintaining the rest of the Internet ecosystem, which will be still left out in the cold.

Remember too, that almost every platform we use to communicate online has been accused (and sued) as a method to encourage infringement. The music industry attempted to sue the MP3 player out of existence as an infringing device (https://www.zdnet.com/article/stop-the-music-diamond-multime... ), the movie industry sued YouTube claiming that it was primarily a device for piracy. https://en.wikipedia.org/wiki/Viacom_International_Inc._v._Y....

3 comments

^ This should be the top comment. Thank you for the excellent summary, and for fighting the good fight!
Are there really specific exceptions for Wikipedia and Github? How does that work? They can't be named explicitly in the law, surely?
The relevant quote from this version [1] is:

>"The definition of online content sharing service providers under this Directive does not cover microenterprises and small sized enterprises within the meaning of Title I of the Annex to Commission Recommendation 2003/361/EC and service providers that act in a non-commercial purpose capacity such as online encyclopaedia, and providers of online services where the content is uploaded with the authorisation of all right holders concerned, such as educational or scientific repositories. Providers of cloud services for individual use which do not provide direct access to the public, open source software developing platforms, and online market places whose main activity is online retail of physical goods, should not be considered online content sharing service providers within the meaning of this Directive."

[1] http://www.europarl.europa.eu/sides/getDoc.do?type=TA&langua...

> online services where the content is uploaded with the authorisation of all right holders concerned,

Does the service trust the uploader about this? There will inevitably be disputes about that self declaration.

It's also impossible to know which are all the rightholder of a piece of content. There might always be one more making a claim later on. Any system, automated or manual, is going to have many false positives and negatives.

On the other side, this system is already in place for traditional media. It's dealt with litigation. Again, no need to create special legislation for the internet. The blame must be passed over to the content creator, not to the distributor. This means that the creator must be identifiable, to know who to sue.

However this means that the supposed rightholder is going to automatically sue a zillion of people, with false negatives. This is unfair. I propose that in case of false negatives they lose the right on the content.

An example.

It's May and they play the final of the Champions League (this is about the EU). People will post the highlights. The rightholder will manually identify some hundreds of those videos, sue the uploaders and win. This will teach people not to upload those kind of videos next time. But if they sue a guy because they mistake him playing with friends as the Champions-League final, they'll lose all the rights on it. They'll be very careful about who to sue, people will be careful about what they upload, I won't see highlights anymore on YouTube but I can live with that. It seems fair for everybody.

The part about losing the rights is not going to happen though so I wasted your time, sorry.

Wow. That doesn't even make sense: "service providers that act in a non-commercial purpose capacity such as online encyclopaedia, and providers of online services where the content is uploaded with the authorisation of all right holders"

Are they really assuming all online encyclopaedias are non-commercial?

Since Github is now part of Microsoft ... it's kind of hard to see them as SMEs, based upon the text of the articles.
> Why would you take that risk? How could you protect yourself against that risk?

Host only original content of which you or your registered users are the declared copyright holders.

Flickr, Smugmug and other enthusiast photo gallery sites seem to have walked this line quite successfully. Imgur and its ilk haven't because they've never really had a reason to care. Now they do.

So YouTube wouldn't be the massive entity it is now if it were truly YouTube and forbade uploading of any derived content. But perhaps that would be better.

MP3 sites might be more like SoundCloud with original content.

I find it difficult to be moved by the protests of people who just want to post other people's creations. Link to it, don't copy it.

> Host only original content of which you or your registered users are the declared copyright holders.

And what magic spell do you expect publishers to cast to distinguish the two when you allow users to post content? Do you have the faintest idea how absurd what you're saying is?

> Host only original content of which you or your registered users are the declared copyright holders.

How would a company go about being certain of this, do you think? I can't think of a way to do it with uploaded content that doesn't have a nasty error rate. Obviously it becomes trivial if you take the Netflix approach and source everything from the owners directly, which means working only with the biggest providers who have legal departments and such. With restrictions like this, even SoundCloud can't exist - almost everything on there is a derived work!

Have I missed something? Can you help me understand how a site can be certain it hosts only original or otherwise authorized content without taking a Netflix-type approach? I would love to be wrong, and for there to be an easy, cost-efficient approach that offers a suitably low error rate and enables protecting content creators while preventing abuses.

> Host only original content of which you or your registered users are the declared copyright holders.

Good luck proving what copyright everything that your users upload has. Such systems cost billions of dollars to develop and are prone to abuse.

> it were truly YouTube and forbade uploading of any derived content

Most content is in some way derived. Forbidding such things would effectively eliminate gaming channels, political channels, music channels, review channels, podcasts etc.

> MP3 sites might be more like SoundCloud

You do realize the RIAA is not particularly happy about SoundCloud either, right? And much content on there can still be described as 'derived'.

> I find it difficult to be moved by the protests of people who just want to post other people's creations.

I find it difficult to be moved by copyright maximalists, who used other people's work to get where thy are, but now insist that they should profit from a piece of work 70+ years after the author is dead.

No memes = no culture.

I am opposed, and will remain so, until such time as the big players either demonstrate real harm, or recognize the many benefits they get.

And they do benefit significantly.

What they claim is always the same,"billions lost", yet fail ti explain where all that money actually comes from.

Entertainment dollars for the vast majority are largely fixed. There aren't those dollars actually out there.

What I find particularly onerous is the idea of not actually being able to put material out there intended to be shared freely. Did that make it into this mess?

It's not just about hosting. It's about linking, too.