Welcome, Mr. Walt Disney, to the Canadian Public Domain

(Disney in 1946 - Wikipedia)

Today is public domain day in Canada for the works of any sole or last surviving joint author who died in 1966. Canada has a copyright term of life + 50 years.

Walt Disney, the person, died on December 15, 1966. This means that any works of which he may have been the sole or last surviving joint author are now in the public domain in Canada as of January 1, 2017. It will be interesting to see if there are such works. In Canada, there can sometimes be legal and factual complexity and uncertainty in the determination of authorship and the copyright term of films.

As anyone who knows anything about copyright law knows, it was The Walt Disney Company that pushed the US Congress and the Clinton administration to extend the American copyright term to life + 70 years in 1998 through the Copyright Term Extension Act, sometimes referred to as the Mickey Mouse Protection Act.

There are no credible policy reasons to extend the copyright term beyond that of life + plus 50 years. However, there are billions of reasons in the form of dollars for shareholders in legacy copyright-based companies, such as Disney, to do so. Not only will revenue streams be extended – but term extension sets up effective barriers or delays to entry for anyone who dares to emulate Disney’s business model that was built upon exploitation and reliance upon the then much more recent entry of works into the public domain. Here is an article in Forbes by Derek Khanna entitled 50 Disney Movies Based On The Public Domain.

Indeed, those who believe in innovation should strongly oppose term extension. There is no substantial incentive value to any living creator – and obviously no incentive value whatsoever to dead creators – involved in the theoretical possibility of windfall revenues for great-great grandchildren and even beyond. Indeed, excessively effective copyright protection can serve as a disincentive to creativity. See F.M. Scherer’s brilliant book Quarter Notes and Bank Notes: The Economics of Music Composition in the Eighteenth and Nineteenth Centuries.  He suggests that “In the case of Verdi, greater remuneration though full exploitation of the copyright system led perceptibly to a lessening of composing effort.” (p. 194). Verdi, of course, is high if not on top of the pantheon of opera composers. Copyright is not the only and arguably far from the most efficient tool to incentivize literary, dramatic, musical and artistic creativity.

Canada, China and many other countries have not followed Disney’s company’s wish to extend the copyright term to life + 70 years. I take some credit for stopping a stealth move by the Canadian Government to extend the copyright term in 2003. Here’s my “Mouse in the House” National Post op-ed that played a significant role in that resistance. Canada, to its credit, held the line on the life + 50 term in CETA – even though the EU had long since gone to life + 70 even before the Americans. However, the now apparently dead TPP (which Canada had signed) would have extended the term to life + 70 in Canada.

If NAFTA is really going to be reopened as Trump threatens, look for American pressure as focussed and amplified through the usual Canadian lobbyists to escalate the Canadian copyright term to life + 70.  Hopefully, Canada will stand its ground.  The previous Government shamefully snuck through a 20 year term extension in 2015 for sound recordings in an omnibus budget bill at the behest of lobbyists for the American recording industry. I wrote the following on November 17, 2015 based upon a recent New Zealand government study:

Assuming that the New Zealand study methodology for calculation of the cost of a 20 year copyright term extension were to be more or less applicable to Canada and that the results would be more or less proportional to the difference in GDP, here are some admittedly “back of the envelope” calculations:

The average present value of the cost of 20 year copyright for recorded music and books term extension (which included an estimate for film and television) was estimated by NZ is NZ $505 million, which is CDN $434 million, which adjusted by GDP ratio, would work out to about CDN $4.176 billion.

The average annual cost for NZ is NZ $55 million, which is $CDN 47.3, which adjusted by GDP ratio, would work out to about CDN $454 million.

Other notable creators who died in 1966 include:

•  Lenny Bruce, comedian
•  Alberto Giacometti, painter and sculptor
•  Evelyn Waugh, author
•  C.S. Forester, author
•  Buster Keaton, actor and director

Canada welcomes them and Mr. Walt Disney himself to the public domain in Canada.

HPK

What's Wrong With This Picture And Where Does it Come From?

What’s wrong with this picture and where does it come from?

It is presumably meant to be an illustration of the fact that a musical composition embodied in a sound recording may be in the public domain while the sound recording may still be protected by copyright, or vice versa. That may not be totally obvious to everyone.  So far, so good – at least in theory.

Both examples superficially seem to take into account the 2015 Canadian legislation extending the copyright term for sound recordings to 70 years from publication, which was a gratuitous and un-debated (because it was buried in a budget bill shortly before an election) gift from the previous Government to the American recording industry.  This was a true triumph of lobbying over logic and evidence, but I digress. Be that as it may, this change came into effect only in 2015 and is not retroactive. Indeed, the Government did make it absolutely clear that this term extension windfall would not revive expired copyrights in sound recordings or performer’s performances:

2015, c. 36, s. 82No revival of copyright82 Paragraph 23(1)(b) and subsection 23(1.1) of the Copyright Act, as enacted by section 81, do not have the effect of reviving the copyright, or a right to remuneration, in a sound recording or performer’s performance fixed in a sound recording in which the copyright or the right to remuneration had expired on the coming into force of those provisions. (highlight added)

Therefore, the example where the CD was presumably fixed and published in 1945 is clearly wrong. The copyright in that sound recording would have entered the public domain in Canada at the latest 50 years after the end of 1945 -– in other words December 31, 1995. The copyright in this example would not have been revived by either the 2012 or the 2015 legislation so as to get any extra term of protection. In any case, it should be needless to say that there were no CDs in 1945. State-of-the-art at the time was 78s. Even LPs did not come on the market until 1948. CD’s arrived in the only in the 1980’s.

The non-retroactive application of the 2015 twenty year term extension for sound recordings is very important – because there’s a treasure trove of high quality classical, jazz and rock recordings from the 50’s and early to mid-sixties that have now entered the public domain in Canada – subject, of course, to possibly still extant copyright in the music embodied therein. Indeed, there is a very important case (Stargrove) relating to this unfolding at the Competition Tribunal*, which Michael Geist has covered extensively.

The example on the left suggests that if a composer died in 1800 (nine years after Mozart’s death), his or her work entered the public domain in Canada in 1850. However, the first Canadian copyright legislation was not in place until 1832.  The life + 50 term did not become the law of Canada until 1924 and is still the law for literary, dramatic, artistic and musical works.  Therefore, the example is not useful. It would have been more interesting and informative to have a more recent date of death, such as 1911 – the year of death of Gustav Mahler (one of the most important composers of the 19^th and 20^th centuries), concerning whom we have seen even recently surprising confusion and overreaching claims of copyright protection.  See here and here.

These examples show a disappointing misunderstanding of Canadian copyright law, both current and historic. This might not be particularly noteworthy, given so many other misinterpretations and errors that we have seen over the years emanating from trade associations, universities, Government institutions and even authors of books and blogs about copyright, some of which I have chronicled over the years.  Oversimplifying copyright law, despite the best of intentions, can sometimes be dangerous. However, in this case, the source of this problematic posting about Canadian copyright law happens to be the Copyright Board of Canada itself.

It’s from the Copyright Board’s latest attempt to explain – and perhaps to justify - its resource intensive “orphan works” regime. This information is presumably addressed to lay readers. The information provided is certainly not helpful to copyright lawyers.

True, some kind of orphan works regime is required by s. 77 of the Copyright Act. However, why it requires so much resources and has achieved such dubious results is another matter. This regime uses up at least one staff FTE and presumably some member time, since only a Board member can issue a ruling. As I commented in 2014:

…. Even if it is only one person or FTE equivalent who works on these files, I would respectfully suggest that this is one person too many. One person year (FTE) per year since 1989 translates at a probably conservative cost estimate of $75,000 per year, including benefits, to about $1,875,000 to date for a process that was clearly absolutely unnecessary in at least 19% of the files and probably a great deal more (perhaps involving insubstantial copying or fair dealing?) – even under the existing legislation. To the extent that more senior staff, including legal staff, and Board members themselves, may have gotten involved, the real cost may have been substantially more. The Board itself recently states  that “a target of 45 days was set between the file completion date and the issuance of the licence”. This suggests that a lot of time may be spent on these files. 

The Board may have well spent more than $2 million of public money to direct about $75,000 or so to collectives through about 277 licenses in circumstances where the collectives have generally nothing to deserve this little windfall.  It should be pointed out that collectives, as required by s. 67 of the Copyright Act  "must answer within a reasonable time all reasonable requests from the public for information about its repertoire of works, performer’s performances or sound recordings, that are in current use."

Barry Sookman, William Vancise (the former Copyright Board Chair) and I got into a heated discussion about all this back in 2014 at Fordham, which I recounted here in a lengthy blog that was very critical of how the Board described and implemented its orphan works regime and why it is a model that has not been and should not be followed anywhere else.  Here’s Barry’s unconvincing response.

I also had some critical words at the time about how the Board had failed to recognize and inform the public about the meaning, significance, and potential of “fair dealing” to obviate the need in many cases to worry about permissions, much less any need to seek a an unlocatable owner license from the Board. I said at the time in 2014:

The Board could easily provide a useful service to the public by updating its website on providing guidance as when a license is NOT needed in the case of an unlocatable copyright owner. As of now, the Board has apparently not updated its website since 2001 on this issue – and thus ignores several key Supreme Court decisions and legislative changes since then. The Board still continues to suggest that:

"You also do not need a licence if the intended use is not protected by copyright. There are a few specific exceptions to the copyright owners' exclusive right to authorize the use of their works "or any substantial part thereof in any material form whatever". For instance, fair dealing for the purposes of research or private study is allowed. So is copying of sound recordings for a person's own private use. However, the courts tend to interpret these exceptions restrictively."(highlight added)

 Quite apart from the inexplicable reference to private copying, the above material was dubious in in 2001, when the Board’s website on this subject was apparently last modified. It has been clearly very wrong ever since the Supreme Court's landmark 2004 ruling in CCH v. LSUC which confirmed that “Research” must be given a large and liberal interpretation in order to ensure those users’ rights are not unduly constrained.”

 The statement is even more blatantly wrong since the SCC’s “pentalogy” decisions in 2012 and the inclusion of “education”, “parody” and “satire” in the fair dealing provisions of the legislation. It should not take more than a few minutes of the time of one of the Board’s four lawyers to update this page by providing, at the very least, links to the current statutory framework as found in s. 29 of the Copyright Act and the three Supreme Court of Canada decisions on fair dealing plus the Cinar decision rendered since 2004 and indicating how these decisions are relevant.

 It appears that the Board has now done a somewhat but not a much better job of explaining “fair dealing” with the following language:

Sections 29 to 29.2 of the Act provide a number of exceptions by which it is possible to use a work without authorization. They are fair dealing for the purpose of research, private study, education, parody, satire, criticism or review and news reporting. What constitutes fair dealing is determined in conformity with criteria established by the courts that are related to the purpose, character and amount of the dealing, the alternatives, the nature of the work and the effect of the dealing on the work.

Courts have interpreted these exceptions as a user’s right. Some of these exceptions require certain conditions to be met (for example the mention of the source for a criticism, review or news reporting)

However, this stops far short of explaining that the Supreme Court of Canada has made certain aspects of the law of fair dealing crystal clear.  For example, it is the law of Canada that “As an integral part of the scheme of copyright law, the s. 29 fair dealing exception is always available “must be given a “large and liberal interpretation” and that the “availability of a licence is not relevant to deciding whether a dealing has been fair”.  These are not my words. They are the words of the Chief Justice of Canada writing for the Court in CCH v. LSUC.

At the very least, the Board should have provided links to the CCH v. LSUC, SOCAN v. Bell and Province of Alberta v. Access Copyright which are the seminal fair dealing decisions of the Supreme Court of Canada. Decisions of the Supreme Court of Canada are the final and binding on all, which is something that some copyright lawyers and even the Board itself on occasion have seemed sometimes reluctant to accept.

It would have also been useful and trivially simple for the Board to provide hyperlinks to the various other exceptions and statutory provisions referenced in this update. For example, instead of simply referring to section 29 of the Copyright act, why can’t the Board refer to it as “section 29 of the Copyright Act” with an embedded hyperlink?

It would have also been useful for the Board to provide examples, with hyperlinks to its own decisions and announcements, to many of the situations where unlocatable licenses are not needed and where seeking them is a waste of everyone’s time. Perhaps the most obvious example is that of architectural plans filed in countless city halls across Canada for which copies are frequently needed for purposes of home renovation. It took the Board many years and a lot of public pressure from your’s truly for the Board to finally relent on this particular point. Who knows how much time and money was wasted because of the Board’s long standing incorrect approach to this particular issue? At one point, as I documented, about 29% of the licenses issued by the Board involved these architectural plans.

It is commendable that the Board has somewhat improved its information with respect to unlocatable copyright owners and partially corrected some long-standing misinformation, albeit with some new misinformation. However, it would be desirable if the language of the posting could be consistent as between “insubstantial” and “unsubstantial”. It would also be desirable if the Board could refrain from careless use of the word “use”, since many non-expert readers may get the wrong impression that any “use” of a copyrighted work requires permission. For example, reading, watching, listening to, talking about, writing about, criticizing, reporting about a lecture given in public, quoting insubstantial excerpts from, quoting substantial excerpts in a manner consistent with fair dealing, linking to, footnoting, reading from in a public lecture, and probably many common “uses” don’t require anybody’s permission. It is not very helpful for the Copyright Board to provide perfunctory information and then simply tell folks to:

“If you think that you don’t need a licence for the use you intend to make, you could choose to obtain legal advice to confirm that one of the above-mentioned situations applies to you.”

Finally, the Board should make it clear that these licenses have costs – sometimes hundreds of dollars in license fees imposed by the Board. This is in addition to any expenditure in terms of time or legal fees to obtain the license. It would be better still if the Board simply stopped charging for these licenses – because they are simply a windfall to a collective that likely has done nothing to deserve the money. For example, quite apart from its limited actual repertoire, Access Copyright has gone to the other extreme and shown remarkable chutzpah for a long time by being willing to license the use of works that are clearly in the public domain, for example a 1915 edition of Charles Dickens (d. 1870) “A Christmas Carol”. One of the more stranger of many strange licenses issued by the by the Board is the license for the publication of two “jokes” – yes, “jokes”. This is subject to a payment of $7.50 for each joke to Access Copyright. I’m NOT joking! Here’s the ruling.

The Board has a budget of about $3.5 million a year, and a staff five times larger than any other copyright tribunal anywhere else in the world (including the USA Copyright Royalty Board). Surely, with these resources, it can come up with a more accurate and useful explanation for laypersons as to when and how to go about seeking a license when the copyright owner is unlocatable.

HPK

*PS: Update September 21, 2016. I've been alerted to the fact that the Stargrove case at the Competition Tribunal has been settled:

http://www.ct-tc.gc.ca/CasesAffaires/CasesDetails-eng.asp?CaseID=388

http://www.ct-tc.gc.ca/CasesAffaires/CasesDetails-eng.asp?CaseID=383

While the settlement is presumably confidential, it would seem that you can still get the Beatles' 1964 CD "Can't Buy Me Love" and several other early Beatles albums for $5.00 each at Canadian Walmart.  That would seem to suggest that the Canadian music industry blinked and backed down. 

Is the Party Over for the "Happy Birthday" Song?

The Happy Birthday song is in the news once again. Watch the video above for what is perhaps the most historic, famous and transparent performance ever of this song. Viewer discretion is advised.

Here is the complaint in a class action lawsuit in the Southern District of New York, which seeks a  declaration that any copyright rights owned by Warner/Chappell are extremely limited (to certain piano arrangements published in the 1930's) and that the song is and has been for a long time in the public domain.

More to the point, it seeks restitution of all license fees paid for the song going back to 2009. Presumably, that date is based upon a limitation period. And that could mean millions of dollars for the lawyers involved, if this succeeds.

Here's a remarkable paper by Prof. Robert Brauneis - which presumably forms the basis for the litigation. Prof. Brauneis told the NY Times:

“I believe this song is in the public domain and therefore it is not owned by anyone,” Professor Brauneis said in a phone interview on Thursday. He said “Happy Birthday to You” was “economically significant” in that it “still produces millions of dollars of income in a year,” and that a successful legal challenge “might be a model for challenges to other songs.”

The law suit has been assigned to the legendary Judge Louis Stanton.

And here's the best arrangement ever of this song - by Igor Stravinsky, the best composer of the twentieth century: 

Speaking of birthday's. May 29, 2013 was the 100th birthday of Stravinsky's Rite of Spring, easily the most influential musical composition in the last century. It is performed here brilliantly by Michael Tilson Thomas and the San Francisco Symphony:

HPK

Public Domain Day 2012 - Welcome to Jung, Jelly Roll Morton, Joyce and Grandma Moses

 

 

 Beautiful World by Grandma Moses (1860-1961)

Today is the day that many works enter the public domain, according to all kinds of very complicated rules and despite the efforts of the likes of The Walt Disney Company and the Estate of Lucy Maud Montgomery to the the contrary. I continue to be pleased that Jack Granatstein, myself, and others were successful in spotting, trapping, and getting rid of the "Mouse in the House" that appeared to be the first stage of a Mickey Mouse Copyright Term Extension movement in Canada. Our 2003 pre-Facebook campaign led to the defeat of the harmful aspects of certain otherwise useful legislation in which the mouse was hiding that would have extended copyright in the unpublished works of LMM, and other important figures such as Prime Ministers Laurier, Borden, and Bennett, as well as Stephen Leacock and Grey Owl for up to 34 years.


The determination of when a work enters the public domain is relatively straightforward in Canada, at least in comparison with the USA. For the latter, see charts by:

• Gasaway
• Hirtle 
• Benedict O'Mahoney 

Moreover, there is a case called Golan v. Holder  under reserve in the US Supreme Court that will determine the validity of US legislation restoring copyright in certain classes of works that have already entered the public domain, including works by Stravinsky and H.G. Wells for example. We should know the outcome by June of this year.

Not only is the determination of when a work enters the public domain in each country very difficult in many cases. The increasing and increasingly dangerous trend towards extraterritorial assertion of copyright law makes it increasingly risky to make available online works that are in the public domain in the country where there the site is hosted but are still protected in other countries.  Uncertainty and some heavy handed threats have impeded the efforts of some very useful websites, such as the IMSLP Petrucci Music Library that have sought to make countless important books and musical scores that in the public domain in Canada and most other countries apart from the USA and EU members as widely available as possible.

I continue to think that harmonization of the public domain term would, in principle, be a useful exercise for WIPO,  were it not for the fact that this would almost certaintly involve eneomrous pressure to harmonize to the highest common denominator of life + 70 as found in the EU and USA. Indeed, the USA may have inflicted  irreversible and irreparable harm on itself with with its unwise term extension, due to its Fifth Amendment constitutional provision that may make the taking back of such an extension effectively impossible, at least with respect to any works covered by the life plus 70 term under a law that was validly enacted.

While one hears that the Europeans may not go to the wall on life + 70 in the Canada - EU (CETA) trade talks, one must be wary of the Americans in the Trans-Pacific Partnership (TPP) agreement negotiations in which Canada has agreed to participate. Whether Canada's willingness to negotiate in the TPP forum with change the dynamic of the CETA talks could be interesting.

Anyway, here is the indomitable Wallace J. McClean's annual Public Domain Day liberation post. According to Mr. McLean, Canadians will now have full access to a trove of previously published works including by the following creators whom  he has seen fit to highlight, according to his eclectic taste:

• Canadian novelist Mazo de la Roche
• British politician and Newfoundland Commissioner Sir John Hope Simpson
• American author Ernest Hemingway
• Swiss psychiatrist Carl Jung
• Swedish diplomat and author Dag Hammarskjöld
• Austrian physicist Erwin Schrödinger
• American writer and cartoonist James Thurber
• American artist Grandma Moses
• American playwright Moss Hart
• American artist Max Weber
• Italian mathematician Beppo Levi
• Serbian poet Branko Miljković
• Nazi war criminal Kurt Meyer (published his self-serving memoir “Grenadiere” in 1957)

Other homages to PD day in the life + 70 regime  can be found  on the 1709 Blog here re James Joyce  and here re Jelly Roll Morton. Canadians, of course, welcomed them into the public domain 20 years ago.

Happy PD day and Happy New Year.

HK

Access Copyright Charging for Public Domain Material

(Pygmalion and Galatea in the public domain)

A comment by one "Sysyphe" on my blog yesterday about Access Copyright ("AC") pointed out how AC is listing PD works in its repertoire for digital licensing. For those outside of Canada, AC is a collective that purports to license reprographic and digital reproduction of books, magazines, newspapers and other publications.

A quick check reveals the same practice in its transactional licensing tool.

Check out the AC licensing wizard,which offers to sell a license to make ten copies of 10 pages of George Bernard Shaw's Pygmalion for $25.00. The inconvenient truth, however, is that Shaw died in 1950 and his work is in the public domain in Canada. This does not speak well for AC's repertoire claims or to credibility in its long awaited and still invisible public domain registry.

HK

Update - July 29, 2009:

The comment from Stephen below is interesting. The particular 1942 edition of Pygmalion I pointed to above does indeed have some still protected illustrations - but AC's Wizard will take my money regardless of which pages I am copying. It should only take my money for the protected pages. (leaving aside the question of whether AC actually has any rights here, which is always interesting).

However, it took me only a few seconds to find another Shavian example of a work clearly totally in the PD where AC is quite happy to take my money. It has photos, but the edition was published in 1931 - so even the photos are now in the PD in Canada. Here's the AC Wizard page for the 1931 NY Dodd, Mead edition of Don Juan in hell : from man and superman. Here's the AMICUS entry for that edition.

Public Domain Day 2009

The ever redoubtable and incorrigibly public-domain-loving Wallace McLean has once again augmented the database of copyright expired luminaries ranging this year from my fav Robert W. Service of the Class of 1958 (a Brit so it seems, though we think of him as Canadian) to American cartoonist E. C. Segar (creator of “Popeye”) of the Class of 1938.

Now, I ask once again, when we may expect Access Copyright's Public Domain Registry, which was proudly announced in 2006 and has now in 2008 supposedly made it to beta testing.

HK

At the Margins of the Public Domain

Since it's Public Domain Day, I thought I'd check on Access Copyright's progress on its much vaunted project to create a public domian registrty in partnership with Creative Commons.

Here's what I found on the Access Copyright website (not to be confused with this blog's "Excess Copyright" name):

To find out about the public domain registry that Access Copyright is working on creating with Creative Commons and the Wikimedia Foundation, please click here.

If you click on "here", this is what you will see:

The page cannot be found The page you are looking for might have been removed, had its name changed, or is temporarily unavailable. ... Technical Information (for support personnel) Go to Microsoft Product Support Services and perform a title search for the words HTTP and 404.

UPDATE JANUARY 5, 2008:

The Access Copyright links above now work. If you click on them, you will be told:

For Immediate Release
March 3, 2006
Toronto, ON – Access Copyright, The Canadian Copyright Licensing Agency and Creative Commons Canada, in partnership with Creative Commons Corporation in the US, today announced the development of a Canadian public domain registry. The ground-breaking project – the most comprehensive of its kind in Canada – will create an online, globally searchable catalogue of published works that are in the Canadian public domain.

Note the date - March 3, 2006.

So far, the only database of Canadian PD works I've seen is from a certain public domain loving gadfly named Wallace McLean. And he doesn't have revenues of more than $30 million a year.

So where is our Access Copyright public domain registry, after almost two years of waiting?????

Dunno - and I'm now an Access Copyright mole member ;)

So, maybe Access Copyright should spend USD $37 (less than that in real CDN $) to get the real inside scoop here at THE PUBLIC DOMAIN PROWLER.

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System Requirements: The Public Domain Prowler comes in .exe format and is designed to run under Windows. If you have an Apple Mac, you will need a PC emulator installed.

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Who said copyright law was dull, boring and geeky?

Happy New Year and caveat emptor - whether in relation to certain copyright collective's announcements or certain 100% Risk-Free Full Money Back Guarante opportunities...

HK