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What forms of behavior in relation to the protectable TCEs/EoF should be considered unacceptable/illegal?


International Publishers Association (IPA)

IPA is concerned by the introduction of the notion of “unacceptability” in the ongoing discussions. “Unacceptability” is not a legal term and means different things to different people. IPA recommends the use of clear and unambiguous terms throughout the ongoing discussions.

IPA could envisage a requirement that the publication or other use of TCEs/EoF should be done only with appropriate acknowledgement of the source.
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China

We think the following forms of behavior are unacceptable/illegal: (1) unauthorized reproduction, adaptation, broadcasting, public performance, distribution, rental, or communication to the public, of TCEs/EoF or their derivative forms; (2) use of TCEs/EoF or their derivative forms without indicating their source; and (3) distortion, mutilation or other modification of, or other derogatory action in relation to, TCEs/EoF.
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Kyrgyzstan

Illegal appropriation, falsification and other actions damaging traditional cultural expressions (folklore) shall be considered illegal actions.
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United States of America

Over the last several years, the IGC has made considerable progress in identifying specific forms of behavior regarded as unacceptable or illegal by indigenous peoples and traditional and other cultural communities. The work of the IB in conducting regional consultations and in sponsoring research has been particularly helpful in facilitating this aspect of the work of the IGC. The members of the IGC also have benefited greatly from hearing directly from representatives of indigenous peoples and traditional and other cultural communities on forms of behavior that are considered unacceptable or illegal.

Despite the wealth of materials that have been generated, it remains difficult to generalize regarding specific behaviors that are regarded as unacceptable or illegal, sometimes broadly called “misappropriation.” Part of the explanation is that views on forms of behavior that may be regarded as unacceptable or illegal vary widely depending on local social, cultural, and economic circumstances. Another part of the explanation is that acts of misappropriation cover a wide range of behaviors. In this regard, the IGC has distilled a broad range of behaviors regarded indigenous peoples and traditional and other cultural communities as unacceptable or illegal, including:

(a)   unauthorized reproduction, adaptation and subsequent commercialization of TCEs/EoF, with no sharing of economic benefits;
(b)   use of TCEs/EoF in ways that are insulting, degrading and/or culturally and spiritually offensive;
(c)   unauthorized access to and disclosure and use of sacred/secret materials;
(d)   appropriation of traditional languages;
(e)   unauthorized fixation of live performances of TCEs/EoF and subsequent acts in relation to those fixations;
(f)    appropriation of the reputation or distinctive character of TCEs/EoF in ways that evoke an authentic traditional product, by use of misleading or false indications as to authenticity or origin, or adoption of their methods of manufacture and ‘style’;
(g)   failure to acknowledge the traditional source of a tradition‑based creation or innovation;
(h)   granting of erroneous industrial property rights over TCEs/EoF and derivatives thereof (footnote in submission: Paragraph 53, Document 7/3.)
Building on this foundation, the IGC should deepen its understanding of these concerns by examining and discussing in detail the existing mechanisms, including legal (both IPR and non-IPR) and non-legal measures, that are available to address these specific issues or concerns. The IGC would then be able identify gaps, if any, in existing mechanisms at the domestic and/or international levels to address the specific issues or concerns.
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Ghana

a.       Unauthorized collection of folklore from the right owners.
b.      Non acknowledge of the rights of the owners or holders of the folklore
c.       Exploitation of the protected folklore without the consent or authorization of the owner of folklore.
d.      Publishing the protected information without the authorization nor observance of the moral right in the folklore
e.       Unreasonable withholding of information on folklore by the holders from researchers.
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Brazil
An international instrument for the protection of TCEs/EoFs negotiated in an IP forum such as WIPO should not overlook the need to provide for measures aimed at curbing acts of misappropriation, specifically those acts that take place via the use of IP mechanisms. Among these measures, the requirement for prior informed consent should apply to all TCEs/EoFs, registered or not. Registration should not be a condition for the enforcement of rights by the communities in question.
Furthermore, one important criterium to assess whether an act constitutes misappropriation is the existence of prior informed consent by the community in question. The requirement for prior informed consent should figure as an important tenet in a system of protection of TCEs/EoFs.
With the preceding provisos in mind, the draft provision put forward in document WIPO/GRTKF/IC/10/4, Article 3, represents adequate basis to discuss the issue:

 “(a) In respect of traditional cultural expressions/expressions of folklore of particular cultural or spiritual value or significance to a community, and which have been registered or notified as referred to in Article 7, there shall be adequate and effective legal and practical measures to ensure that the relevant community can prevent the following acts taking place without its free, prior and informed consent:

(i) in respect of such traditional cultural expressions/expressions of folklore other than words, signs, names and symbols:

the reproduction, publication, adaptation, broadcasting, public performance, communication to the public, distribution, rental, making available to the public and fixation (including by still photography) of the traditional cultural expressions/ expressions of folklore or derivatives thereof;

any use of the traditional cultural expressions/expressions of folklore or adaptation thereof which does not acknowledge in an appropriate way the community as the source of the traditional cultural expressions/expressions of folklore;

any distortion, mutilation or other modification of, or other derogatory action in relation to, the traditional cultural expressions/expressions of folklore; and

the acquisition or exercise of IP rights over the traditional cultural expressions/ expressions of folklore or adaptations thereof;
(ii) in respect of words, signs, names and symbols which are such traditional cultural expressions/expressions of folklore, any use of the traditional cultural expressions/ expressions of folklore or derivatives thereof, or the acquisition or exercise of IP rights over the traditional cultural expressions/expressions of folklore or derivatives thereof, which disparages, offends or falsely suggests a connection with the community concerned, or brings the community into contempt or disrepute;

Other traditional cultural expressions/expressions of folklore

(b) In respect of the use and exploitation of other traditional cultural expressions/expressions of folklore not registered or notified as referred to in Article 7, there shall be adequate and effective legal and practical measures to ensure that:

(i) the relevant community is identified as the source of any work or other production adapted from the traditional cultural expression/expression of folklore;

(ii) any distortion, mutilation or other modification of, or other derogatory action in relation to, a traditional cultural expression/expression of folklore can be prevented and/or is subject to civil or criminal sanctions;

(iii) any false, confusing or misleading indications or allegations which, in relation to goods or services that refer to, draw upon or evoke the traditional cultural expression/expression of folklore of a community, suggest any endorsement by or linkage with that community, can be prevented and/or is subject to civil or criminal sanctions; and

(iv) where the use or exploitation is for gainful intent, there should be equitable remuneration or benefit-sharing on terms determined by the Agency referred to in Article 4 in consultation with the relevant community; and

Secret traditional cultural expressions/expressions of folklore
(c) There shall be adequate and effective legal and practical measures to ensure that communities have the means to prevent the unauthorized disclosure, subsequent use of and acquisition and exercise of IP rights over secret traditional cultural expressions/expressions of folklore.”
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Japan

Unacceptable/illegal acts may vary depending on the form of protection for TCEs/EoF. As mentioned in the above item 3, there is no clear justifiable reason why TCEs/EoF is eligible for IP right protection. Japan is greatly concerned about extending IP right protection to TCEs/EoF. Use of TCEs/EoF that inflict mental suffering upon a community should be refrained from, as a matter of moral in general in the same way that derogatory expressions against certain race, religion or sex should be refrained from. However one should be careful in attempting to establish any system of IP rights or similar rights in order to deter such acts, as unnecessarily rigid regulation against expression could harm freedom of speech or development of culture. Moreover, when defining unacceptable/illegal acts, a fact finding survey should be conducted to find out what damage is incurred by what acts.
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Norway

A common understanding on what constitutes misappropriation is essential to obtain an adequate and effective protection against such misappropriation and unfair use.

Unacceptable behavior includes at least all:
·         unauthorized exploitation for economic gain  
·         exploitation that does not acknowledge the source of the TCE/EoF
·         offensive use

A common, core understanding of at least these three elements are necessary.
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Qatar

Misuse, robbery, unethical infringement, illicit exploitation, prejudicial actions and misappropriation.
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South Africa

         Misappropriation

South Africa is of the view that any acquisition or appropriation of indigenous knowledge, traditional cultural expressions and genetic resources by unfair or illicit means constitutes an act of misappropriation. We further propose that any commercial benefit derived from the use of indigenous knowledge, traditional cultural expressions and genetic resources contrary to any honest practice that gains inequitable monetary advantage constitutes misappropriation. This is also applicable to person/s accessing the knowledge that knows or is negligent in failing to know. Regarding document WIPO/GRTKF/IC/10/4 we query protection against the misappropriation of indigenous knowledge. Our particular concern regards:
         What is fair use and what is misappropriation?
         Is the public domain legitimate?

         Distortion

South Africa is concerned at the rampant manipulation and distortion of indigenous knowledge, traditional cultural expressions and genetic resources. Given the nature of indigenous knowledge, traditional cultural expressions and genetic resources the presentation of indigenous cultural material in a manner of promoting integrity requires careful consideration.

         Contrary to Constitution/ domestic legislation/ international instruments/ human rights

South Africa has a bundle of legislation that seeks to protect indigenous knowledge, traditional cultural expressions and genetic resources hence we are the view that any violation of these pieces of legislation will constitute behaviour which is unacceptable.

         Disrespect/denigration
          
In concert with South Africa’s proposal on access and benefit sharing regulations we support the inclusion of the following text to this sub-section, “Failure to obtain prior informed consent- unauthorised usage.”

We are steadfast in our stance that any person without the prior informed consent of the community uses knowledge, an innovation or a practice in a manner inconsistent with our proposed (draft) access and benefit sharing regulations commits an illegal act.
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Russian Association of Indigenous Peoples of the North (RAIPON)

The unlawful or commercial use of copies of and tunes from works without the consent of the authors and performers.
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Colombia

Article 3 of the substantive provisions contained in documents WIPO/GRTKF/IC/9/4 and WIPO/GRTKF/IC/10/4 considers the protection of expressions of folklore that are registered separately from those expressions that are not registered, even though in relation to copyright registration is declaratory and does not constitute rights. Protection is derived solely from creation and therefore the Government of Colombia does not agree to consider registration and notification as a condition for the exercise of the right to prior informed consent. The moral and economic rights protected should be the same and have the same enforcement measures (civil, criminal and administrative). 

As regards the TCEs/EoF of cultural and spiritual value, it is important to consider that some indigenous peoples have expressed the view that, where different levels and types of knowledge exist, those should be dealt with differently, but precisely those which are in the spiritual dimension should be seen from a defensive perspective, since in principle economic interests do not exist in between, but expectations of a transcendental and spiritual nature. Consequently, strict protection must exist and mechanisms distinct from registration or notification be established in order to regulate and make the right to prior informed consent effective.

A sui generis system of protection must establish a limit on those TCEs/EoF which, owing to their spiritual and sacred nature, cannot be commercialized. Peoples and communities have their own authorities which must protect and keep custody of such knowledge with their specific legal and justice systems, and the competent national authority shall be responsible for protecting this right and strengthening the authorities and organizations of peoples and communities so that they may exercise the right.

Similarly, the existence of scientific evidence of collective ownership of TCEs/EoF must be sufficient proof to enjoy the right to prior informed consent, even where registration or notification does not exist in the competent government bodies for the protection of intellectual property rights. Scientific evidence includes ethnographical studies, monographs, scientific compilations and publications, produced both by social and natural scientists, and by members of the communities which carry out specific research as a strategy to recover and revitalize TCEs/EoF.

Furthermore, in complex geopolitical contexts, the major expectation of cultural communities relates to guaranteeing their physical and cultural continuity, owing to the different kinds of pressure which they face. In these contexts, the protection of TCEs/EoF moves on to another level but, for a different reason, such expressions cease to be legal subjects and therefore requirements must not be established which in certain cases are unachievable for communities. In other words, the rights of the most vulnerable peoples and communities must be guaranteed as a matter of priority and without condition in contexts of conflict and displacement.
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Federación Ibero-Latinoamericana de Artistas, Intérpretes y Ejecutantes (FILAIE)

In general, any form of appropriation, in the broad sense of this concept, which can be reflected in specific civil, administrative or criminal provisions.

In general, the looting to which peoples and communities are subject by third parties must be avoided, which logically implies intellectual property protection and knowledge thereof, with relevant registrations designed to produce an inventory/register in relation to third parties.
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Tunisia

ü  Piracy, unauthorized use of such knowledge.
ü  Copying (counterfeiting).
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Guatemala

Model Provisions for National Laws on the Protection of Expressions of Folklore Against Illicit Exploitation and Other Prejudicial Actions (WIPO/GRTKF/IC/2).

Commercialization on a global scale without due respect for the cultural and economic interests of the communities in which they originated and without the peoples that are authors of their expressions of folklore receiving any share of the benefits of such exploitation.
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Russian Federation

Taking into consideration the provisions cited in point 3, the unacceptable forms of behavior should be:
·         illegal appropriation of authorship;
·         acts of use of works of folk arts harming the dignity of the representatives of peoples the works of folk arts of which are used.

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