Tuesday, June 19, 2018

A response to Article 13

Managed to write to my MEPs about the awful proposed EU's Copyright Directive Article 13 - you can submit a response via ORG here, but for my own reference, this is my hastily-written missive:


Dear Sir/Madam,

I am writing to express my extreme concern about the proposed changes under Article 13 of the Copyright Directive, due to be voted on very shortly.

Having been involved in the internet and online innovation for over 20 years, and acting currently as Technical Director for a small UK company, I believe in several points:

1. That it is imperative to our economic and social resilience that  innovation and communication remain free from burdens of overhead except where proved absolutely necessary

2. That the proposed legislation will increase the cost and risk of any new innovation, with broad, damaging effects to the development of society and discourse as a whole, at a time where we require appropriate innovation and resilience

3. That the legislation will increasingly push innovation and communication into unmonitored and unmonitorable networks, with the result that appropriate support and/or integration of such services will become harder, again to the detriment of an already-fragmented society

4. That the proposed legislation relies on technology that has distinct, specific drawbacks - namely that it encourages a more centralised digital ecosystem with increased risk of lower resilience as a result, and that there are insufficient safeguards to ensuring the technical solution can be monitored, audited, and maintained effectively.

5. That the legislation would introduce a lop-sided split between responsibilities, ie. it does not make sense to rely on a more centralised structure to provide the algorithms to implement the law, but push overall responsibilities on those parties not in charge of the algorithms, but would merely need to outsource this functionality, given the excessive cost of building such a filtering service from scratch.

In short, the Article threatens the business case of any small-to-medium business incorporating user input, threatens to upset innovation and conversation to the detriment of the economy and society generally, and risks a confused legal structure to discourage further innovation.

I urge you to vigourously vote against this legislation, and to address the underlying issues in a way that is more sustainable, technically feasible, and legally clear.

Kind regards

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