Section 29 of the Copyright Act contains one of the most important user rights in Canadian copyright law – fair dealing for the purpose of research or private study does not infringe copyright.  For many years, this provision was narrowly defined such that the education and library communities adopted relatively conservative approaches to defining what constituted fair dealing.  In recent years, however, Canada has experienced a dramatic shift in the vibrance and importance of fair dealing.  In a trio of cases, the Supreme Court of Canada strongly affirmed the need for balance in Canadian copyright law.  The shift began in the Theberge, where Justice Binnie, in discussing the copyright balance, stated that: