<<< Date Index >>>     <<< Thread Index >>>

[IP] Bullied List Needed To Counter Trade & IP Linkage





Begin forwarded message:

From: Michael Geist <mgeist@xxxxxxxxx>
Date: May 9, 2005 7:04:21 AM EDT
To: dave@xxxxxxxxxx
Subject: IP Bullied List Needed To Counter Trade & IP Linkage


Dave,

Of possible interest - my weekly Law Bytes column (posted below) focuses on the recent USTR Special 301 report and its specific criticisms of Canada's copyright plans. The column highlights the gradual escalation of U.S. linkage of trade and intellectual property protection and calls for the creation of new IP Bullied List that would include at least a dozen countries bullied into agreeing to stronger IP laws, along with a Bullied Watch List that would include dozens of countries currently negotiating similar trade agreements.

The IP Bullied List would include at least the following 12 countries -- Australia, Bahrain, Chile, Singapore, Morocco, Jordan, and the signatories to the Central America Free Trade Agreement (Dominican Republic, Costa Rica, El Salvador, Guatemala, Honduras, and Nicaragua). Each of these countries has reached trade agreements with the U.S. that include sizable intellectual property requirements.

The Watch List would be even longer, including individual countries such as Panama, Thailand, Malaysia, and Brunei that are all working on bi-lateral trade agreements. Moreover, a block of Middle Eastern countries (Algeria, Kuwait, Qatar, Saudi Arabia, United Arab Emirates, and Yemen) would make the list as part of the Middle East Free Area Initiative as would the five countries working on the Southern African Customs Union Free Trade Agreement (South Africa, Botswana, Lesotho, Namibia, and Swaziland). Further, every country in the Americas, including Canada, Mexico, Argentina, Brazil, Jamaica, Peru, and Venezuela would be on the list by virtue of their participation in the Free Trade Area of the Americas Agreement negotiation.
Freely available hyperlinked version at
http://www.michaelgeist.ca/resc/html_bkup/may92005.html
Toronto Star reg. version at
<http://geistipbulliedlist.notlong.com>

MG


TRADE PRESSURES CLOUD INTELLECTUAL PROPERTY POLICY

Michael Geist

Late last month the United States released its annual report on the state of global intellectual property protections. Officially called the "Special 301 Report" after the legislative provision that mandated the annual review by the U.S. Trade Representative, it places countries deemed to have insufficient protections on either a "Watch List" or a "Priority Watch List". Inclusion on the Priority Watch List is particularly troublesome since that may lead to U.S. trade sanctions.

Indeed, the U.S. deemed Canada's intellectual property laws insufficient for the eleventh consecutive year. We are, however, in good company - the U.S. cited 50 countries including the European Union and dozens of nations in South America, Eastern Europe, Asia, the Middle East, and the Caribbean.

While media attention in Canada focused on the U.S. concerns over the availability of counterfeit or pirated products at home, the coverage missed the real story. Just weeks after the Canadian government announced its plans for copyright reform, the U.S. has injected itself in our policy debate by criticizing our future laws as well.

The report notes that the U.S. copyright industry is concerned with the Canadian plan, a reference to Ottawa's intent to reject some of the provisions found in the controversial U.S. Digital Millennium Copyright Act. In particular, the U.S. is unhappy with both Canada's proposed approach to legal protections for digital locks known as technological protection measures (TPMs) as well as with its proposal for Internet service provider liability.

After years of calling on Canada to implement the World Intellectual Property Organization's Internet treaties, the U.S.'s true interests have been revealed. Implementing the treaties is now not good enough. Rather, the U.S. wants us to implement its version of the treaties, which extend well beyond international requirements.

Even more troubling is the way U.S. pressure against Canada has become part of a much larger global campaign to leverage its economic power by tying trade agreements with greater intellectual property protection. This was not always the case - when Canada negotiated the free trade agreement with the United States in the 1980s, intellectual property issues constituted only a small part of the agreement. Similar U.S. agreements with Israel as well as the subsequent North American Free Trade Agreement also referred to intellectual property but did not make it a focal point.

Today the U.S. is negotiating trade agreements with dozens of countries. The intellectual property provisions within those agreements are sometimes at least 40 pages in length, specifying international intellectual property agreements that must be implemented and including specific provisions to govern domain name disputes, patent protection, and copyright law. The copyright provisions inevitably go beyond even those found in the U.S., since they include requirements for an extension of the term of copyright, new protections for TPMs, and ISP liability requirements. They do not, however, feature any balancing provisions for user interests.

This trade policy approach has become so pervasive that the time has come to create a mirror list to counter the U.S. Special 301 report. That list should include those countries already bullied by the U.S. into adopting stronger intellectual property protections along with a "Watch List" of other countries currently facing similar pressures.

The IP Bullied List would include at least the following 12 countries -- Australia, Bahrain, Chile, Singapore, Morocco, Jordan, and the signatories to the Central America Free Trade Agreement (Dominican Republic, Costa Rica, El Salvador, Guatemala, Honduras, and Nicaragua). Each of these countries has reached trade agreements with the U.S. that include sizable intellectual property requirements. For example, the U.S. - Morocco Free Trade Agreement even includes ministerial side letters specifying precisely what ISPs in Marrakesh are required to do in the event that they receive notification that one of their subscribers has posted infringing content on the Internet.

The Watch List would be even longer, including individual countries such as Panama, Thailand, Malaysia, and Brunei that are all working on bi-lateral trade agreements. Moreover, a block of Middle Eastern countries (Algeria, Kuwait, Qatar, Saudi Arabia, United Arab Emirates, and Yemen) would make the list as part of the Middle East Free Area Initiative as would the five countries working on the Southern African Customs Union Free Trade Agreement (South Africa, Botswana, Lesotho, Namibia, and Swaziland).

Further, every country in the Americas, including Canada, Mexico, Argentina, Brazil, Jamaica, Peru, and Venezuela would be on the list by virtue of their participation in the Free Trade Area of the Americas Agreement negotiation.

Even though that draft treaty has stalled, the FTAA is the U.S.'s most ambitious attempt to spread stronger intellectual property laws throughout North and South America with at least 25 countries participating in the talks. The latest version includes pages of intellectual property obligations that would overturn carefully developed national policies. For example, the Canadian Internet Registration Authority would be required to scrap its domain name dispute resolution policy, since it provides greater protection for free speech websites than the policy favoured by the U.S.

Given its global trade strategy, the U.S.'s recent criticism of Canada's plans is clearly just the first shot across the bow. If history is any indication, Industry Minister David Emerson and Canadian Heritage Minister Liza Frulla can expect an onslaught of U.S. backed lobbying for stronger protections in the months ahead.

Standing up to that pressure is difficult, but Ottawa should keep in mind that it is far better to retain Canadian sovereignty and in doing so remain on the U.S. Special 301 list, than to surrender our right to choose and take a spot on the U.S. IP Bullied List.
--
**********************************************************************
Professor Michael A. Geist
Canada Research Chair in Internet and E-commerce Law
University of Ottawa Law School, Common Law Section
57 Louis Pasteur St., Ottawa, Ontario, K1N 6N5
Tel: 613-562-5800, x3319     Fax: 613-562-5124
mgeist@xxxxxxxxx              http://www.michaelgeist.ca


-------------------------------------
You are subscribed as roessler@xxxxxxxxxxxxxxxxxx
To manage your subscription, go to
 http://v2.listbox.com/member/?listname=ip

Archives at: http://www.interesting-people.org/archives/interesting-people/