Mr. Chairman,

European Digital Rights represents 21 privacy and civil rights organizations from 14 different countries all around Europe.

EDRI warmly welcomes Brazil's recent proposal to balance the existing proposal. EDRI also endorses the earlier statements from CSC, FIM and EFF.

To reiterate shortly our own position:

• The inclusion of webcasting and simulcasting - which are essentially the same - does not really make sense at this point since nobody really knows to what direction the technology and business models are moving in the future. Even worse, the current proposals seems to discriminate against grass root activities like podcasting and thus favor the big existing traditional organizations.

• The period of protection should be - at max - 20 years. Even the patents, which require typically significantly higher investments, enjoy that term of protection. It really should be enough.

• The treaty should not include technological protection measures. The current experiences pertaining TMPs in protection of copyright do not show any real success in limiting unauthorized copying - but instead - a very real success in limiting users' legitimate rights to use their legally obtained works.

• Finally, we would like to see much more impact assessment studies on what effects different proposed options could have on the markets. For example, we haven't seen yet any independent evidence that lack of "broadcast right" is currently a real problem for webcasters.