Canadian Copyright Reform In Force: Expanded User Rights Now the Law

This morning, the majority of Bill C-11, the copyright reform bill, took effect, marking the most significant changes to Canadian copyright law in decades. While there are still some further changes to come (the Internet provider notice-and-notice rules await a consultation and their own regulations, various provisions related to the WIPO Internet treaties await formal ratification of those treaties), all the consumer oriented provisions are now active. These include:

  • The addition of education, parody, and satire as fair dealing purposes.
  • The creation of a non-commercial user generated content provision that creates a legal safe harbour for creators of non-commercial UGC (provided they meet four conditions in the law) and for sites that host such content. 
  • The adoption of several new consumer exceptions including time shifting (recording of television shows), format shifting, and the making of backup copies.
  • Changes to the statutory damages rules that distinguish between commercial and non-commercial infringement. The law now includes a cap of $5000 for all non-commercial infringement. The change reduces the likelihood of lawsuits against individuals for non-commercial activities and would apply to educational institutions engaged in non-commercial activity and significantly reduce their potential liability for infringement.
  • The inclusion of an exception for publicly available materials on the Internet for education. This covers the content found on millions of websites that can now be communicated and reproduced by educational institutions without the need for permission or compensation.
  • The adoption of a technology-neutral approach for the reproduction of materials for display purposes. The current law is limited to manual reproduction or on an overhead projector. The provision may be applicable in the online learning context and open the door to digitization activities.
  • The implementation of a distance learning provision, though use of the exception features significant restrictions that require the destruction of lessons at the conclusion of the course.
  • The inclusion of a restrictive digital inter-library loans provision that will allow for digital transmission of materials on an inter-library basis, increasing access to materials that have been acquired by university libraries.
  • A new exception for public performances in schools, which will reduce licensing costs for educational institutions.
There are several other notable provisions and exclusions. First, although the notice-and-notice provisions for Internet providers have not taken effect, but the decision to stop short of the U.S.-style notice-and-takedown or a notice-and-termination rule is a huge victory for Canadians that provides a balanced approach safeguarding privacy and access to the Internet.  Second, the government also rejected an expansion of the private copying levy.  In fact, the government today also published regulations specifically excluding MicroSD cards from the levy. Third, the law includes an “enabler provision” that will make it easier for rights holders to sue sites or services that facilitate infringement.

Fourth, the digital lock rules are now also in effect. This was the most controversial aspect of the bill as the government caved to U.S. pressure despite widespread opposition to its restrictive approach. There are some exceptions to the digital lock rules (including for law enforcement, interoperability, encryption research, security, privacy, unlocking cellphones, and persons with perceptual disabilities), but these are drafted in a very restrictive manner.  The government has established a regulatory process to allow for new digital lock exceptions, which creates the possibility of Canadians seeking new exceptions to at least match some of the U.S. exceptions on DVDs or streaming video. At the moment, Canada is arguably more restrictive than even the U.S., though the digital lock rules do not carry significant penalties for individuals. Under Canadian law, it is not an infringement to possess tools or software that can be used to circumvent digital locks and liability is limited to actual damages in non-commercial cases.

As I wrote earlier this week, copyright is part of a sea change in digital policy making in Canada. In 2007, the government was hours away from introducing a bill that contained virtually no user-oriented provisions. Today, a bill took effect that has its flaws but also creates some of the most expansive copyright user rights in the world.

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  1. examples
    So, for those of us who have not dealt with the ins-&-outs of copyright law before, can you provide some examples of what each of these changes mean for users? We would appreciate that!

  2. Something wrong in line about possessing digital locks?
    I am confused by what you mean by “it is not an infringement to possess digital locks”?

    How do I “possess” a digital lock? Is this a typo? Do you mean to posses means of opening digital locks?

  3. Thank you Michael
    You were a great advocate for this balanced approach and represented the general public extremely well. I saw you on CSPAN and you have my sincerest thanks.

    In my eyes you had a clear and direct impact on this law and you should be proud of that!

  4. I’m curious about the locks part. Does this mean that if the content has a lock, the user rights are useless? If something as simple as ROT13 is used on the content, that means that it’s illegal to format-shift it? Or what? If so, that means the expanded user rights are near-useless as you must commit an illegal act to do any of the rest.

    Or am I interpreting this incorrectly?

  5. Kevin, yes you are. The government in classic free market philosophy decided that market forces would be sufficient to protect the same user rights in the bill. I suppose we will see if they were right (not holding breath).

  6. Angry Burner says:

    Media Levy
    WIth the media levy to compensate copyright holders for losses, are we still able to download music legally?

  7. The “digital locks” (aka DRM) provision will be OK only if it is enforced only the people that sell copied DVDs, etc.

    Otherwise we will go back to the days of jukeboxes to have a DVD/CD collections.

    BTW: How long does Copyrights last in Canada? Infinity plus a day like in the US?
    When was the last Copyrighted book/movie/etc actually became Public Domain (Canada or US)?

  8. Thanks for your tireless advocacy!!
    I think your efforts went a long way to ensuring a more balanced Canadian copyright law Michael. Thank you for your tireless advocacy for the rights of Canadians!!


  9. Yes I concur with Phil, Mr. Micheal Geist, you have definitely helped shape copyright reform in Canada, now can you please run for Prime Minister, please.


  10. Darryl Moore says:

    You can’t break DRM on cell phone!!!
    Sorry Michael, I am not a lawyer, but I believe you are quite wrong regarding the rules on DRM and cell phones.

    I think you are reading this section of the act to conclude that cell phones are exempt from DRM liability.

    41.18 (1) Paragraph 41.1(1)(a) does not apply to a person who circumvents a technological protection measure on a radio apparatus for the sole purpose of gaining access to a telecommunications service by means of the radio apparatus.

    However this only applies to “gaining access to a telecommunications service”. It does not apply to running software. Pirated, your own, or otherwise. Apple and Google lock people into purchasing software via their app stores, and not allowing them to load software onto the devices directly.

    Jailbreaking or rooting your cellphone is not always necessary to change cell phone providers, but it is necessary in order to control all the software on the device. The latter is not covered by the above exemption.

    While you might be able to do certain things in order to access telecom services, you are still restricted in your ability to control the actual software which runs on your devices. This is a policy which 180 degrees in the wrong direction of what we need to protect consumers and their personal, and very real property.

  11. There are inherent problems with C-11…
    Let me begin by saying right up front that I believe the fair-dealing exemptions in this bill are a genuinely good thing.


    The core problem with the bill is that these exemptions can be revoked entirely at the discretion of the content maker who can simply decide to utilize a digital lock.

    This is an inherent self-contradiction. If fair dealing was allegedly a reasonable exemption to copyright infringement, then why should a choice that the consumer has no part in making (the decision to utilize a digital lock) change that? Even at best it’s irrellevant, and it’s a damn-near certainty that most Canadians aren’t going to care about this at all when they are engaging in practices that still may qualify as fair dealing, and allegedly could have been completely exempt from copyright infringement, but are suddenly illegal just because of a lock’s presence. Consumers may have a choice to not buy such locked content, but by offering legal protection for digital locks, the government has created an added value incentive for publishers to utilize them, and this so-called “choice” that consumers have is restricted by the actual availability of unlocked and alternative content, which in the face of the added value that locks might have for publishers, is only going to get smaller in the future. Even worse, many Canadians who even know about the bill are not wholly unlikely to be indignant enough about the matter to seek already pirated and unlocked sources of the content that they desire online, dodging the issue of them having personally broken the locks involved, but at the same time endorsing the activities of people that *do* break the law… an entirely hypocritical approach to take for anyone who allegedly desires to abide the law.

    To top it all off, the conservatives have even gone on record as telling people to not even be concerned about this law with regards to private copying… which itself doesn’t make any sense, since if Canadians weren’t supposed to be trying to abide by the law in such private matters, then why does the law even explicitly exclude such private copying from being an exemption to infringement in the first place?

    This bill is so utterly and inherently self-contradictory with anything that a respectable government could pass that it is inevitable to be ignored by most Canadians at their convenience, privately or otherwise.

  12. Re: You can’t break DRM on cell phone!!!

    You said in your comment “Apple and Google lock people into purchasing software via their app stores, and not allowing them to load software onto the devices directly.” That’s incorrect. APPLE does this. Google does not. Some providers that sell Android (google) phones do this to the phones they sell. Google does provide an app store, and by default that’s the only path to installation, but in your Android phone’s settings, there’s a checkbox for “Allow installation of non-Market applications”. This means you can install an Android .apk (application) from anywhere you wish.

    So you’re right about Apple. You have to “Jailbreak” their phones in order to load whatever you wish, but this is not true of Android. Even many Android manufacturers are allowing the ability to “root” their phones from instructions on their websites. This is by default not enabled because it’s a security risk, but it’s still possible to do.

    Now in principal I agree that we should be allowed to root and side-load whatever we want on our own hardware, be it a computer, a cell phone, or a game console. Attention does need to be brought on this, but Google’s not the villain here. Apple(iPhone)/Microsoft(Xbox & WinRT)/Sony(PS3 + everything they ever touch)/Amazon (1984 tactics related to ebooks) and some wireless providers are by trying (and sometimes succeeding) at locking you out of your own devices.

  13. Re: Daryl Moore
    “Apple and Google lock people into purchasing software via their app stores, and not allowing them to load software onto the devices directly.”

    Google does not lock you into purchasing software via their app store. There is a checkbox on all Android phones that allows you to load apps from other App Stores (e.g. the Amazon App Store) and directly downloaded from websites, no rooting required.

  14. Re: D.
    “BTW: How long does Copyrights last in Canada? Infinity plus a day like in the US?”

    Life + 50 years

  15. “The creation of a non-commercial user generated content provision that creates a legal safe harbour for creators of non-commercial USG”

    Did you mean UGC (user generated content)? If not, what do you mean by USG?

  16. librarian
    what does the “USG” in the second bullet stand for??

  17. Sad day in Canada
    Ith a sad day today. We, courtesy of the Conservatives, lost PRIVATE COPYING, which means you can no longer share mixtapes with friends, duplicate discs you own or build a library of Canadian content by borrowing and ripping disks. Duplicating a disc now has a higher penalty than stealing one!

    I am disappointed in my MP, and I’ll be running against him.

  18. Copywrite example @D
    An example is that most of H. P. Lovecraft’s works are now out of copyright in Canada and most of the rest of the world, but not in the USA.

  19. Shawn H Corey says:

    What are these four conditions?
    “The creation of a non-commercial user generated content provision that creates a legal safe harbour for creators of non-commercial UGC (provided they meet four conditions in the law) and for sites that host such content.”

    What are these four conditions?

  20. Darryl Moore says:

    Kevin & Ryan
    Ummm, thanks for the clarification…. I guess. I haven’t actually seen this checkbox on my Galaxy and I know there are many things I still cannot do such as editing the host file or running various services without rooting, but whatever. Whether Google does it or it is just apple, or it is a local garage door manufacturer doesn’t matter. My point is that your cell phone is not yours any more. The manufacturer can and sometimes does control it without your explicit permission, and there is nothing legally you can do about it any more. In one very narrow way this new law gives consumers more power, but in a much more significant way, consumers have lost a lot of power and control over their cell phones and other personal property.

  21. console
    so am i allowed to use “tools” and “software” on my own console and i am fine? adn those that sell “tools” is that fine, or is that too illegal.

    kinda funny usa just passed new DMCA to allow cell phone unlocking for any cell bought before 2013, but after that its illegal, i guess cell telcos got to the washington lobbyists (after seeing how much money was being made on unlocking) and want that pie to eat as well. but i guess its ok to unlock cells in canada still but not jailbreaking. but consumers can unlock but can companies still sell “tools” to unlock phones or do unlocking for as a service?

  22. Cell Phone “Rooting”
    With respect to the Android comments above… Many phones sold in Canada don’t have restrictive bootloader locks (which is what prevents you from installing your own software). Most HTC phones for instance can be unlocked through a tool on HTC’s website. This wouldn’t be considered circumvention since it is a service provided by the manufacturer of the device. My carrier (Rogers) chooses to allow me to use that tool. Some other carriers (AT&T for instance) do not allow HTC to provide that service to phones sold through them. So that is something to be aware of when selecting both your hardware and your telecommunications provider. Vote with your wallet! Oh and note that none of the locking or unlocking is in any way controlled/administered/operated by Google. It is between the hardware manufacturer and the carrier who sold the device to the end user.

    Once the bootloader is unlocked, you can install whatever software you like, without restrictions. This does NOT require you to “root” your device (hacking the carrier supplied software), rather it gives you the option to replace the carrier supplied software with something else. “Something else” can be virtually anything.

    None of the above is true for the iPhone – they will not unlock the bootloader for you no matter what, so you can only run software images digitally signed by Apple. Likewise many Motorola phones have similar restrictions, though some others can be unlocked. Always best to check what you are buying as this is now a “feature” that the end user can choose to either have or do without.

    Also note that the “Nexus” phones always have an unlocked bootloader, and can run any software you want.

  23. Bryn, as has been pointed out already, you don’t need to “root” Android phones simply in order to install non-Google Play applications; all you have to do is select a checkbox.

  24. Wonder how long it takes for the car manufactures to start suing small business to force them to buy their diagnostic equipment other wise get sued for copyright infringement/drm circumventing.

    Watch your next electronic device will automatically have a reset feature that only “authorised” dealers can reset when a component is replaced.

    Way to shaft the consumer. Not our fault the some industries can’t adjust their business models that flow with the times.

  25. Adam Williamson says:

    On private lock breaking
    If I’m reading the post correctly, it’s effectively not going to be a problem for anyone to circumvent DRM for personal use:

    “Under Canadian law, it is not an infringement to possess tools or software that can be used to circumvent digital locks and liability is limited to actual damages in non-commercial cases.”

    Note ‘liability is limited to actual damages’. If I buy a DVD and then use dvdcss to play it using my Linux-based PC, so far as I can tell, no-one has suffered any damage. The DVD publisher hasn’t, because I bought the DVD, after all. They got their money.

    I suppose the makers of a ‘legitimate’ DVD playing application could argue they suffered damage in the form of me not buying their app…but I don’t think that kind of creative thing really flies in court. IANAL, but based on the above, I seriously doubt anyone breaking DRM for personal use in a way which doesn’t actually result in lost revenue for anyone is going to get dinged. Limiting the damages also means it’s just not going to be worth taking anyone to court for anything below really high levels of infringement. It only works in the U.S. because they have punitive damages for personal use infringement.

    If I’m wrong, I’m sure someone will correct me…

  26. Darryl Moore says:

    More on private lock breaking
    When you downloaded DeCSS and/or VLC you were probably importing a circumvention device, and hence breaking the law.

    When you ripped your DVD, you were liable only for actual damages, but were still none the less, breaking the law.

    When you ripped the DVD for your friend were were sadly again, breaking the law.

    If there is no intention to prosecute for these ‘crimes’ and indeed the government makes an extra effort to ensure that there is no financial motivation for such prosecution (for at least some of them), then what purpose do these laws serve? From my perspective the only thing they accomplish is to reinforce the notion that copyright law is archaic and outdated and should simply be ignored. This in my mind undoes any of the good which might have been had from the modernization of the fair dealing provisions.

    As for actual damages, I suspect the copyright owner could come after you for damages because you converted to a medium which he could have sold to you instead. It is the continuation of the whole LP -> 8-track -> TAPE -> CD -> MP3 -> DRM planned obsolescence model of marketing you are circumventing. Not just a single DVD.

  27. If you download something, let’s say a clip from Youtube, does this mean you’ll get in trouble now that this has become law?

  28. @ Blue Shoe
    “We, courtesy of the Conservatives, lost PRIVATE COPYING, which means you can no longer share mixtapes with friends, duplicate discs you own or build a library of Canadian content by borrowing and ripping disks. Duplicating a disc now has a higher penalty than stealing one!”

    Ummm…didn’t you read the part on “The adoption of several new consumer exceptions including time shifting (recording of television shows), format shifting, and the making of backup copies.”?

    It means you can still make “private copies” or backup copies of your CDs or whatever. I’ll take it with a grain of salt for now until the other provisions are set. I wouldn’t be surprised though if those other provisions are going to be associated with the TPP and or the “Lawful Access from the dead” provisions.

  29. Does the U.S. have digital locks on their contents as well? Just curious.

  30. Abandonware
    Was any progress on Abandonware? when can it be legal to ditribuite software that the is not produced anymore by its author ?

  31. Digital locks
    I wear glasses which were prescribed to me by a doctor for reading. I am wondering if this makes me a person with ‘perceptual disability’ and therefore gives me an exemption so I can break the drm on my kindle books to read them on my Kobo.

  32. Richard Ellis says:

    Is there any indication of when the two WIPO treaties mentioned in the Canada Gazette will come into force?

  33. @Adam:

    Not a problem at all… for people who don’t have any actual desire to retain their integrity and uphold the law.

    It will still be illegal, but the conservatives have gone on record as telling Canadians that they won’t have to worry about it for cases that are strictly private.

    This is categorically the most asinine thing I’ve ever heard, because the government is in practically as many words *actively* endorsing its citizens to be closet lawbreakers.

    If it issues surround private circumvention wasn’t ever going to be a problem for Canadians, then circumventing for strictly private reasons should have been an exception to the digital lock protections in the first place.

  34. The digital lock provision trumps everything else..
    Here’s the thing – anything can be encrypted. So, what are we allowed to do? If I have a DRMed movie, can I record it off the screen? Is that circumventing the digital lock? Can I take screenshots of ebooks that are DRMed?

    Also, what’s been missed here – you have the right to timeshift – but not to *keep* the recording for archiving. You’re expected to buy that even though it was broadcast over the air.

    I find myself reminded of the A for Andromeda fiasco where the BBC erased their copy of the show in 1960 and had vigourously persued people who copied the show off air (as amazingly diffcult as that was in 1960). Then they realised that the show was a classic piece of British TV and they had destroyed the only copy.

    They had to enact a copyright amensty and begged the ‘criminals’ to return any copies so they could reconstruct the original.

    To date: barely half of the six episodes have been reconstructed.

    I fear for society when copyrights trump culture.

  35. @Mr. A BlueShoe is talking about private copying, e.g. I borrow a CD from the library and make a copy for myself, then return the CD. Or I borrow a CD from a friend, etc. That is not a back-up copy.

    In general, the copyright industry has a great victory in the digital lock clauses. Soon, in a few years, we’ll sew the introduction of the ‘broadcast flag’ which is DRM to prevent you from timeshifting/recording.

    It’s the well-known Sliding Scale strategy the copyright industry used for over a 100 years.

    Our salvation lies with the European Parliament, urge any Europeans you know to vote for a EFA/Greens group member party in 2014

  36. Disappointed with new bill
    I voted for the Conservatives last time because I am, for the most part, fundamentally opposed to the freewheeling spending habits of those on the left. That said, this bill, amongst others, is making me less and less impressed. This isn’t the Conservative government I want. It’s not that they’re pro-big business (that’s largely the arena of the Liberals), but they’re caving to foreign pressures, both American (which, itself, doesn’t worry me too much as our two countries have, for the most part, common interests) and Chinese (which does scare the bejeebers out of me). What I don’t like, is our national policy being directed by foreign ENTERTAINMENT companies – this is utterly stupid! Stupid and not in the interests of ANY Canadian – rich or poor, black, white or native. The copyright act does need to be modified, but all countries around the world are being pressured to adopt a USA DMCA-style reform (it’s not just us that got this particular shaft). I gather it’s so we can buy a copy of Transformers at our local Walmart rather than having to try to import it from the USA. I think our politicos are simply running scared and saying Yessir, rather than realizing that, if the world held up a big middle finger to the USA copyright act, American studios would have no choice but to relent (they’d lose the majority of their market).

    So, I don’t think I’m voting Conservative next time around. I certainly won’t vote for the Liberals (not unless they can do a complete 180 turnaround, dump their current stock of old boys and load the party with fresh faces and fresh, new ideas – that make sense and aren’t nutjob ripoffs) or the NDP or God-forbid, the Greens, so I’ll probably have to look toward whichever protest party is running in my area.

    Politics anywhere these days is very disappointing: the current crop of puppets (from ALL parties) offer nothing to inspire hope or the desire to follow. Stephen Harper is a good leader (whether you think his ideas are right or wrong, he’s got people motivated to follow him) but, in the wings of the Conservative party, I see noone to step up and take over, nor do I see any such talent in the other two major parties. And the Americans are even worse off with Obama and Romney being the best they can prop up?!? Very very sad. I’m going back to work now.

  37. Here’s an idea…
    …just ignore whatever the Canadian (or any other) Government says or tells you to, or must, can or should do.

    Our best interest is never their interest (we are fairly low on the list, after themselves, their friends, foreign governments, foreign corporate interests, local corporate interests, etc) so why even pay attention to any of this non-sense.

  38. Does the digital lock have to work right?
    I ask because of an odd situation, following a public library download of time-limited media. The media was disabled on official software on my PC after 21 days as expected but I forgot I’d copied it to an MP3 player. Several months later I noticed it there and it still worked fine! On closer inspection the library service seems to rely on an “honour system” for users to delete player transfers manually. It’s not clear to me if the new law would consider this illegal DRM breaking.

  39. This crosses easily into the realm of the absurd.
    Technically, even *REMEMBERING* what you saw on screen could be considered a circumvention of the digital locks that were in place when you watched a movie with such locks, since the information in your own brain is, in some sense, a form of a copy.

    The “copy” in your head might not be a digital copy, but the law does not govern that… it makes circumventing digital locks without permission illegal, period (with only a very small number of exceptions that pertain very specifically to computer and network security or to law enforcement). As the locks are not still in place in your head, they have been effectively circumvented… just as much as if you had used recording equipment to record the digitally protected work while it was playing on screen (which is *definitely* considered circumvention).

    Of course, the reason why it is ludicrous to regulate what people are merely allowed to remember is that memories are an obvious example of “private use”. But private use does not qualify for any sort of exemption for breaking digital locks on a copyrighted work.

    As technology advances, however… and people in the future may even start to augment their own brain functions with computer equipment (enabling things such as telepathic access to the “internet”, or whatever global networking structure replaces it, to give just one example, or to help improve memory, especially for medical reasons), what people are allowed to merely think about could even start being regulated by laws like this.

    Private use *MUST* be an exemption to infringement…. if it is not, then absolutely everybody becomes a lawbreaker. And as of yesterday morning, everybody is.

  40. Student
    Given 99.9% of content shared on the net is U.S. content the $5000.00 cap is useless for Canadians. Infringe on U.S copyright(s) its their laws that come in to play not Canada’s.
    Private Uses, up load to the net private goes out the window!
    Non-commercial Uses, anyone ever see a blog or site with Ads???
    Why all the joy and celebration folks?

  41. geoffrey boom says:

    don’t forget people! Vinyl records aren’t digitally locked, so if you want to make copies of your music, buy vinyl records and record them! Wooo! Backtracking societyy!

  42. How are they going to enforce laws for
    online infringement? Yes, it’s pretty
    evident that someone could be caught
    rather easily by using the torrents.
    The chances maybe a little higher for
    being nabbed downloading off a file
    locker site like Rapidshare?

    What about Ytube or similar tube sites?
    Unless there would be some collusion for
    Youtube to collect peoples IP addresses,
    and then handing them over to content
    owners, how else would someone be
    caught downloading? How would even
    the people who run Ytube know if someone
    is downloading the content off their site
    or not.

  43. Sorry, meant to say the chances
    may be a little lower somewhat for someone downloading
    off a file locker site, like RS?

  44. VPN
    It would appear the VPN business is going to be booming pretty soon. The Rapidshares among them log your connection, but a lot do not log anything. You might as well make the switch; before long the “account holder is responsible” balloon will be floated here as well.

  45. streaming
    +1 ripping youtube or using VPN’s.
    Ripping youtube videos is the same as viewing them if using software, if it’s from a website (eg: keepvid) then it depends on the site. Suing someone for ripping a freely available youtube video is ridiculous IMHO – I think it should be considered timeshifting. Some services (Spotify) already offer offline use, why doesn’t youtube? If they still don’t like it, embed ads into the video itself. Posting copyrighted stuff on the other hand, probably will be enforced.

  46. As far as I know, it’s downloading copyrighted
    vids to your hard drive which would be illegal.
    Just viewing them should not be illegal at all.

    If the content on Youtube or whatever site
    is copyrighted, then it should be the site’s
    obligation and liability to take the content
    off, especially if notified by a content owner.

    And Ytube has actually been pulling a lot of
    copyrighted videos off their site, the last
    little while.

    Anyone should have the right to view whatever
    is available on Youtube or any other legal
    site. Watching is not the same as downloading.
    It’s not as if the people who are watching the
    copyrighted vid are actually keeping it for
    their own personal use.

  47. @Blueshoe
    “Duplicating a disc now has a higher penalty than stealing one!”

    But, duplicating a disc you haven’t paid for *is* stealing. That’s the point.

  48. Thank you for this article
    Thank you Michael for putting out this article. I found it in the Toronto Star and it’s one of those things that is super helpful but can’t be easily found anywhere else.