CBC v. SODRAC (technological neutrality, nature of the reproduction right)
- the risks taken by the user,
- the extent of the investment made by the user in the new technology, and
- the nature of the copyright protected work’s use in the new technology.
1. multiplied;
2. durable; and
3. material, in the sense that the copy "matters".
The first two criteria, multiplication and durability, have been established in previous caselaw (see Théberge v Galeria d’Art du Petit Champlain Inc, 2002 SCC 34; Bishop v Stevens, [1990] 2 SCR 467; and Entertainment Software Assn v Society of Composers, Authors and Music Publishers of Canada, 2012 SCC 34). The final criterion originates from the language of the statute itself. CIPPIC contended that Parliament’s use of the words “in any material form” is not merely in reference to the substance in which a work is embodied, but rather, to engage the reproduction right, a copy of a work must matter; it must be "material".
CIPPIC suggested that there is ample authority to illustrate that Parliament granted an inherently limited right to reproduce. The word “reproduce” is ambiguous, as evidenced in the 4-3 split decision in Théberge on this exact issue. The modern approach to statutory interpretation requires that “reproduce” be interpreted purposively. Other indicia that the reproduction right is inherently limited include Parliament’s overall purpose, the statutory scheme as a whole and the practical implications of any less rigourous standard of "materiality".
While some might view the technical loopholes in the statute (i.e. sections 30.8 & 9) as evidence of Parliament’s intent to achieve balance, CIPPIC took issue with this loophole approach. In enacting these loopholes, Parliament might have simply wanted to achieve greater certainty with respect to these specific copies. In any case, it would be unrealistic to view these loopholes as a solution to technological innovation. Technological innovation is both inevitable and unpredictable. Rather than engage in a game of legislative catch-up in response to new technologies, Parliament has essentially "future-proofed" the Act through the principle of technological neutrality. Technological neutrality applied in this manner means that legislative amendments are not necessary every time unpredictable technological innovations enter the marketplace.
CIPPIC’s public-interest framework, if adopted by the Court, will allow it to apply the principle of technological neutrality in a manner that is consistent with the balance already embedded into section 3. The end result is that authors will continue to be compensated fairly for multiple, durable copies, and not every time a party realizes new value from technological innovation.
- Appellant Factum - Canadian Broadcasting Corporation
- Respondents Factum - SODRAC 2003 Inc. et al.
- Intervener Factum - Centre for Intellectual Property Policy and Ariel Katz
- Intervener Factum - Canadian Musical Reproduction Rights Agency Ltd
- Intervener Factum - Music Canada et al
- CIPPIC's Intervner Factum