7. Technology Protection Measures (TPMs)
7.1 Telecom supports the Ministry's proposed retention of protection against circumvention of TPMs that control copying.
Access Protection
7.2 Telecom also considers that protection should be extended to TPMs that control access. This step is a logical and necessary one, given the extension of copyright protection to works communicated to the public regardless of the technology used. Access protection performs a similar function in relation to communication rights in digital and electronic formats that copy protection provides in relation to reproduction rights.
Permitted Circumvention
7.3 Telecom comments on the following proposed permitted exceptions:
- The exception for error correction should be sufficiently wide to encompass error detection as well as this activity is often a precursor to error correction.
- Telecom submits that the proposed exception allowing circumvention of TPMs for interoperability should not be established. Permitting circumvention for interoperability would enable undue commercial benefit without compensation for the content owner by allowing systems to be interconnected regardless of the circumvention prevention technology used. This goes far beyond permitting error correction in relation to the copyright work itself.
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