May 20, 2022

Full Text of Library Copyright Alliance Statement to WIPO Regarding Limitations and Exceptions for Libraries

The Library Copyright Alliance includes ACRL, ALA, and ARL.  It is dated July 25, 2012.

From the Statement:

The Library Copyright Alliance expresses appreciation to Member States for your thoughtful discussions regarding limitations and exceptions for these three broad areas that affect the daily

work of libraries: VIP, libraries, and education.

We strongly oppose language in the proposed text for Article D of SCCR/23/7 regarding the provision of aggregated data to rightsholders. It would invite publishers to second-guess the

procedures of libraries as authorized entities, to challenge the quality and quantity of the records kept or the appropriateness of transactions, and to threaten litigation when they see an increase.

These record keeping and reporting activities involve significant costs better spent on the provision of services, and compliance may impose such a burden that many libraries will decide

not to provide services to print disabled patrons. There is no evidence that authorized entities anywhere that exceptions exist have abused those exceptions. So there is no justification for the

added administrative burden.

Furthermore, with current technology, there’s no such thing as anonymous aggregate data. Several major privacy breaches occurred because people were able to reverse engineer the

aggregated data to figure out personally identifiable information. This provision, therefore, threatens the privacy of the visually impaired.

Read the Full Text (2 pages; PDF)

About Gary Price

Gary Price ( is a librarian, writer, consultant, and frequent conference speaker based in the Washington D.C. metro area. Before launching INFOdocket, Price and Shirl Kennedy were the founders and senior editors at ResourceShelf and DocuTicker for 10 years. From 2006-2009 he was Director of Online Information Services at, and is currently a contributing editor at Search Engine Land.