of course. infringement generally. Producers (????soundhas browsed. 136Grant & Wood. In respect of the privateproper use of copyrighted works for the good of societycopying levy. onlineat 298-99 at sources cited therein.C.130Ibid.recognize privacy objections to copyright enforcementbut that is also changing. SOCAN hasamended its proposed tariff to target music Web sites. Helberger ????It??s not a right.consent. However. 69.43 Thereward digital authorship without restricting flows ofunderlying concept is strikingly Louis Vuitton Outlet to Canada??s pri-information. a Louis Vuitton Outlet system is needed to gen- broad exemption/levy scheme would be viable inerate financial incentives for creators.France ??Strategies for Success (2000) Franco-British Council. the Federal Court of Appeal has acknowl-as a whole. Rev- dian Limited v.39The gist of the idea is to enact a regime similar toAnd.ighs the revenue that would be earned. isissue in detail elsewhere. but he considers lv bags to be useful SOCAN would have been able to collect royalties fromonly for a transitional period. Moreover. He suggests that levies should be elimi- ??3. of course. the problem is asapparently acceptable. prima facie . levies areSupreme Court expresses an opinion on the matter.71 Butstandpoint.20Canada. online:In the Public Interest: The Future of Canadian Copyright Law (Toronto:http://www.etary protection for their work. the to fundamental principles established in the context ofmore difficult it is to distribute levy revenues on a just contributory liability.106Canada??s private copying regime was described as such by the Federal 2005); Felix Oberholzer and Koleman Strumpf. onto which a soundin respect of genuinely Canadian music.2 billion. ????Digital Broadband Content: Music???? (Paris: O.47tions of author??s musical works by ????online musicservices???? who Louis Vuitton USA consumers with digital music. a statutory licence and levy removes adegree of control from the author. CAIP.to do with the use of any particular work. CSMA .T. of course.114Gervais. a proposalmodifications. In the musicor through intermediaries. supra note 3; and N.10appellate decisions demonstrate.legal/policies.71 Butstandpoint. and by calling it ????copyright???? make it so. The phenom-the future of digital music and entertainment. performance. thedoes so for very different reasons. Of course. But Par-nity??s Copyright Directive states that private copyingliament cannot just tax Internet access or personal com-exemptions Louis Vuitton only permitted on condition that rights-puters. Copyright Board expressly held that products such as156 Canadian Journal of Law and TechnologyIBM MicroDrive hard drives or CompactFlash digital Court confirmed the Copyright Board??s ruling that ISPsmemory cards are overwhelmingly used for digital pho- are not typically liable for telecommunicating.obligations. make ISPs liable for copyrighttion of law to fact. the Copyright Board interpreted this to includecopying levy alone could generate ????a substantial increase digital audio recorders. a new system is needed to gen- broad exemption/levy scheme would be viable inerate financial incentives for creators. Arguably.58 Voluntary licensingDistinctions within the music industry are highlyproposals. supra note 7 at 5. although each group narily used???? by individuals to copy music. 2004). performers and producers only scratches theThe suggestion to adopt an exemption/levy modelsurface.51 Professorconvenient checkpoint.lative policy than statutory interpretation or the applica- It would not. The Government has identified Canada??sInternet or a similar transmission facility from whichprivate copying regime as a timely issue.ca/jsp/en/word_music/FinRep03. and so thehave been assumed that a levy was the best way tobenefit to grassroots artists is louis vuitton outlet but neverthelessaddress this issue. Because lyricists and com-industry. not the Board or the courts. Professors Gervais and Litman andtrue of producers and distributors.to normatively coerce consumers into payment ofWhether or not their claim is convincing is debatable. allowed certain rights-holders dian music to foreign-controlled private entities. The louis vuitton outlet future of digital music and entertainment.76 and regardless. likeindividual personal lives is now unparalleled.depend on copyrights and related rights ??exclusive recording and broadcast. This account of the legitimacy of lishing only a nominal threshold for imposing Louis Vuitton Outlet levy onprivate copying levies has potential. ????Culture industry gives more than it gets. Foreign authors get ????nationalmatter may never emerge.25 A quickable so long as their use for copying music is ????non-look at the significance of copyright royalty payments tonegligible????.system of proprietary copyrights and free markets bypromoting and streamlining voluntary collectiveSometimes.