The copyright consultation has one of its biggest days today with a major town hall in Toronto, a roundtable hours before, and increased media coverage. The consultation has attracted growing attention in recent weeks as the chart on submissions below demonstrates. There are now over 3,000 submissions with the overwhelming majority of them speaking out against Bill C-61, anti-circumvention rules, and for stronger fair dealing (earlier charts here, here, and here).
Unfortunately, the chart is not entirely accurate in part because the government has effectively been altering some of the submissions. This issue has arisen because of the large number of Canadians that have chosen to use the CCER submission form service. The service allows anyone to submit their comments by either using a form letter or modifying the content as they see fit. The government has decided to treat virtually all submissions from the CCER IP address as the form letter and simply added the relevant name to a single copy of the letter (the chart below reflects the fact that each letter is, in fact, an individual submission. Note that this is not limited to CCER, the government is doing the same thing for a form letter from the Canadian Private Copying Collective). I am reliably told that 10 to 20 percent of people who use the CCER site modify their submissions. The government's approach has wiped out those modifications entirely by adding names to a letter that they did not sign.
I raised this concern with Industry Canada yesterday. They responded:
Industry Canada does not alter submissions. They are posted as received. We recognize participants using the form letter may alter the contents of the letter to best express their personal positions and opinions. Every effort is made to identify variance in the contents of these form submissions. When we receive a form submission which also reflects a personal position, it is posted on the web site as a formal submission, in its original format.
While that may be intent, I have been provided multiple examples of original or modified letters that have not been posted to the site but rather have simply had the authors' names added. For example [update: for a second example, see the letter posted at the end of this post from Cody Faulker of Barrie, Ontario), Justin Ruf of Yorkton, Saskatchewan, is listed as having signed the CCER letter and does not have an individual submission. Yet this was his submission (posted with permission):
