Hernandez, Normida: Copyright Protection in Works of Government

I. Introduction

The Intellectual Property Code or RA 8293 took effect on January 1, 1998. One of the areas contained in the said Code is Copyright which is a legal protection to the intellectual creations in original and derivative literary and artistic works. The Code defines the works that are covered under Copyright Law and those that are not including its limitations .One of the works not covered are those produced by the government. Here, copyright becomes a fulcrum on the need to provide access to public information on one hand and the preservation of the author’s economic and moral rights on the other.

The advent of technology has prompted certain government agencies, institutions and instrumentalities, through its employees, to take further steps to make public data/information more accessible to the public while preserving its integrity. The approaches vary from one country to another, depending on the existing legal environment. The World Intellectual Property Organization (WIPO) copyright Treaty recognizes a need to balance the following interests (1)the need to maintain a balance between the right of authors and the larger public interest, particularly education, research and access to information as reflected in the Berne Convention ; (2) the balance as one between encouraging competition and providing incentives to innovation and creativity on one hand and ensuring access to info on the other and (3) the development of digital technology has led to debate over what the appropriate balance is, in the light of new means to access which may allow unauthorized/high quality reproductions but also allow access to be restricted.

This paper attempted to compare copyright protection on works of government of the Philippines with selected countries and discuss issues and concerns arising thyerefrom.

II. Copyright Protection on Works of Government

A. Concept of Works of Government

In the Philippines a government work is one prepared by an officer or employee of the Republic of the Philippines as part of person’s official duties while in the US from which the Copyright Law of the Philippines was largely based, works of government pertains to work prepared by an officer or an employee of the US government as part of the person’s official duties finds application only to the work of federal government and not to state or local government.

In Bangladesh and Pakistan, the Government has copyright in “Government works”, defined as works made or published under the direction or control of the Government, or any court, tribunal or other judicial or legislative authority in their respective countries. There is no publication criterion: Copyright Act 1985, 2(4). In India, the Government is the first owner of the copyright in any Government work, defined as being any work which is made or published by or under the control of the Government or a Government department, any Legislature in India, or any court, tribunal or other judicial authority in India (Copyright Act 1957, ss.2(k), 17(d)).

The New Zealand Copyright Act 1962 followed the lines of the U.K. Copyright Act 1956 as regards Crown copyright, but the recently passed New Zealand Copyright Act 1994 provides that(1) Crown copyright subsists in a work made by a person employed or engaged by the Crown under a contract of service, a contract of apprenticeship, or a contract for services: duration, 100 years from the end of the year in which the work was made (25 years for typographical arrangement) and (2) No copyright subsists in any of the following works whenever those works were made: Bills introduced into the House of Representatives, Acts of Parliament, regulations, bylaws, New Zealand Parliamentary debates, House of Representatives select committee reports, judgments of any court or tribunal, reports of Royal Commissions and certain other official reports (s.27). However, it is understood that these provisions will only come into effect at a future date, providing a transition period for existing arrangements.

Sec. 178.3 of RA 8293 provides that , “in the case of work created by an author during and in the course of his employment, the copyright shall belong to:

a. The employee, if the creation of the object of copyright is not a part of his regular duties even if the employee uses the time, facilities and materials of the employer;

b. The employer, if the work is the result of the performance of his regularly-assigned duties, unless there is an agreement, express or implied, to the contrary”:

Sec. 178.4 of RA 8293 likewise provides that, “in the case of a work commissioned by a person other than an employer of the author and who pays for it and the work is made in pursuance of the commission, the person who so commissioned the work shall have ownership of work, but the copyright thereto shall remain with the creator, unless there is a written stipulation to the contrary.”

The copyright ownership therefore of government employees in the Philippines depends on the nature of the work and on the agreement entered into by the government with its employees. Contractors and grantees are not government employees and hence their works are protected under copyright.

The US government maintains that not all government publications and records are government works. Government publication refers to an informational matter that is published as an individual document at government expense or as required by law while government records covers all books, papers, maps, photographs, machine readable materials and other documents, materials regardless of physical form of characteristics, made or received by an agency of the US Government under federal law over connection with the transaction of the public business and preserved or appropriate for preservation by that agency or the legitimate successor as evidence of the organization, functions, policies, decisions procedures, operations or other activities of the Government or because of informational value of the data. Library and museum material made or acquired and preserved solely for reference or exhibition purpose, extra copies of documents preserved only for the convenience of reference and stocks of publication of processed documents are not included.

B. Copyright Protection in selected countries

Copyright is not the only means that a government can use to protect its political, national security, commercial and financial interests, information and other control mechanisms can sometimes produce the same results. Unlike Queen of England, President of US can’t sue copyright laws to recover damages for unlicensed publication of a presidential speech leaked to press. Although the First Amendment to US Courts and the Freedom of Information Act served as basis for federal info policy, copyright prohibition is being recognized as increasingly important in an era of digital information, computer networks and economically valuable government databases. A policy against government copyright is not unusual in many foreign countries, Great Britain, Canada and other British Commonwealth countries have a tradition of Crown Copyright .

There are in the U.K. three categories of protection to be taken into account in relation to the texts of statutory, Parliamentary, Governmental and judicial material: (1) copyright in the material itself (i.e., in the Act, Bill, Parliamentary paper, Government document, etc.); (2) copyright in the report of judicial or parliamentary proceedings (including copyright in reports of judgments);(3) copyright in the typographical arrangement of published editions. In addition, there may be a separate literary copyright in headnotes, summaries, case comments etc. There is the further complication that material of foreign origin may be protected under these headings. It is, therefore, not only as regards Crown copyright that there may be constraints on the use of material within the ambit of such copyright. There is also the aspect that statutory, Governmental and judicial material may now be exploited through internationally linked database services.
The composition of Acts of Parliament, Bills and judgments will normally involve an original or creative input, and the same applies to many items of Government publications; it is submitted that, from the copyright point of view, there is no sound reason for discriminating against these and similar official or judicial productions by removing them from the ambit of protection. On the other hand, it is undoubtedly in the public interest that the citizen should, with the least possible hindrance, be able to ascertain the content of his or her country’s laws, Government documents, judgments and judicial pronouncements.

In Canada, you have to apply for copyright clearance on works of government of Canada to ensure access to the most accurate, up to date version. Government copyright must be retained to ensure accuracy and integrity of government materials. The exercise of Crown copyright is often combined with permissive licensing to reproduce materials –as in federal law.

It is difficult to see how copyright provides an incentive for government to create in many cases given that government is bound to carry out its functions. While government material is produced using public money without copyright protection there is a risk that some of this material will no longer be produced. In some cases government will be exposed to risk in developing certain material required by the public because it might be unable recoup any costs incurred. While government material is produced using public money w/o copyright protection, there is a risk that some of these materials will no longer be produced.

Western Australian Dept. of Industry argues that if governments generate copyright material the right afforded as reward for creativity can be utilized or commercialized for the benefit of the people; to remove copyright would destroy or seriously damage a potentially valuable driver of economic development in Australia.

The Law Council of Australia favored amendment of the copyright Act along the lines of New Zealand- no Copyright subsists in bills, legislation, regulations by-laws , parliamentary debate, reports of select committees, judgments and reports of commissions or inquiries (www.ag.gov.au).

The only example of an EU State where the copyright law contains provisions similar in concept to those of the U.K. is Ireland: the Copyright Act 1963 provides that the Government is entitled to copyright on the “Government making or direct control, or first publication” criteria, similar to those under the U.K. 1956 Act (s.51 of the Irish Act, see also savings of other rights or privileges, s.60). Broadly speaking, it can be said that texts of laws, official reports and judgments are excluded from protection under the author’s right laws of the EU Continental States.

Under the German Author’s Right Law 1965, laws, orders, government reports and decisions are excluded from protection (art.5): there are similar provisions in the Austrian Author’s Right Law 1936, art.8. There are no specific provisions in the French Code on Intellectual Property 1992, but jurisprudence and practice exclude protection for statutory and official material, and judgments. There are, however, local variations, e.g. the Swedish Author’s Right Law 1960 has, in regard to official maps, an exception to the general rule of exclusion (art.9). German law recognizes government documents as part of law or officers’ decree or edict or if they have been released as an official announcement or for public information and hence not protected by copyright.

In Greece, the economic right on works created by employees(under any work relation) of the Government or a legal entity of public law in execution of their duties is transferred to the employer, unless provided otherwise by contract.

In some cases the laws make reference to foreign material or translations. The Italian Author’s Right Law 1942 excludes from protection “official acts of the State and of the public administrations, whether Italian or foreign” (art.5). The Spanish Intellectual Property Law 1987 excludes from protection statutory and official material, and judgments, as well as official translations of these texts (art.13).

If the local law does not make specific reference to foreign official material, the question arises as to whether such material is protected in the respective EU States, all of which are members of the Berne Union. The Berne Convention (1971 text) provides certain minimum rights for all protected authors: the rights include the right of reproduction (Art.9), and the protected authors are those who are nationals of one of the countries of the Union, or authors who are not Union nationals, in respect of works first published in a Union country (Art.3(1)).

Article 2(4) permits Union countries to determine the protection to be granted to official texts of a legislative, administrative and legal nature, and to official translations of such texts. Masouyé reads this as covering “laws, administrative regulations and decisions of courts and tribunals”.

If a particular EU country it transpires that the exclusion of official material from protection does not apply to foreign originated material, then the EU author of the material will be able to claim the extended period of protection (70 years p.m.a.) provided under EC Directive 93/98.

Section 105 of the U.S. Copyright Act 1976 provides that copyright protection is not available for any work of the U.S. Government. However, Nimmer states that section 105 applies only to works of the U.S. Government, not to works authored by foreign Governments. “The latter presumably remain protected under American copyright laws, if qualified by virtue of proper foreign origin”.

In the US works by federal government are under public domain but images on government agency websites are not necessarily public domain such that it is advisable to always look for the copyright notice. Works of most state and local governments are subject to copyright with exceptions –those commissioned by US government but produced by contractors unless copyright is assigned to US government. Commercial use of some federal images such as identifying insignia or identification is prohibited.

Copyright act speaks about domestic copyright. Works produced by contractors under government contracts are protected and restricted under US Copyright Law. Holdership of copyright depends on the terms of the contract and the type of work undertaken. Contract terms and conditions vary between agencies.

Federal Acquisition Regulations (FAR) general rights – government has unlimited rights in all data first produced in the performance under a contract and published in academic, technical , professional journals , symposia proceedings or the like , unless the contractor asserts a claim to copyright or the contract provides otherwise.

Non Copyright rule does not apply to state or municipal government of District of Columbia, Puerto Rico or original territories under jurisdiction of US Government the State of Florida and Minnesota require most works produced by government to be under public domain.

US government employees are not prevented from securing copyright in a work written at that person’s own volition and outside his or her duties even though the subject matter involves the government work or professional field of the official or employee

In the US, State and Local government exploit the commercial value of information they collect by claiming copyright in compilations embodying it or on such compilation effectively in the public domain by virtue of State open recorder laws.

There is no infringement is committed subject to the following limitations : fair use, compulsory licenses, use and copying of libraries and sale of work by the owner.

Internet materials are covered by copyright : notice on home page – terms and conditions (not required but good practice to put copyright notices on government web sites; agency policy differs. Hyperlinking does not itself violate Copyright Act since no copying is involved

In the case of Jack B. Pfeiffer vs. Central Intelligence Agency, et al, USCA, Dist. Of Columbia Con., August 1,1995 , the Court held that the government can’t prevent the reproduction of its works (classified information apart) seems a fair enough interpretation, by no stretch of the interpretative imagination however, that a copy of a government work can’t be the Government’s property. Ownership of a copyright is distinct from ownership of any material object in which the work is so embodied.

C. Works Not Protected in the Philippines

In the Philippines, The Law on Copyright treats the matter in Chapter IV, Works not Protected, thus:

Sec. 175. Unprotected Subject Matter. – Notwithstanding the provisions of Sections 172 and 173, no protection shall extend, under this law, to any idea, procedure, system method or operation, concept, principle, discovery or mere data as such, even if they are expressed, explained, illustrated or embodied in a work; news of the day and other miscellaneous facts having the character of mere items of press information; or any official text of a legislative, administrative or legal nature, as well as any official translation thereof.

Sec. 176. Works of the Government. –

176.1. No copyright shall subsist in any work of the Government of the Philippines. However, prior approval of the government agency or office wherein the work is created shall be necessary for exploitation of such work for profit. Such agency or office may, among other things, impose as a condition the payment of royalties. No prior approval or conditions shall be required for the use of any purpose of statutes, rules and regulations, and speeches, lectures, sermons, addresses, and dissertations, pronounced, read or rendered in courts of justice, before administrative agencies, in deliberative assemblies and in meetings of public character.

176.2. The Author of speeches, lectures, sermons, addresses, and dissertations mentioned in the preceding paragraphs shall have the exclusive right of making a collection of his works.

176.3. Notwithstanding the foregoing provisions, the Government is not precluded from receiving and holding copyrights transferred to it by assignment, bequest or otherwise; nor shall publication or republication by the government in a public document of any work in which copy right is subsisting be taken to cause any abridgment or annulment of the copyright or to authorize any use or appropriation of such work without the consent of the copyright owners.

As provided in the said law therefore, copyright protection does not extend to official text of a legislative, administrative or legal nature, as well as any official translation thereof, which the law considers as an unprotected subject matter. Also, on the works of the government, it is expressly mandated that no copyright shall subsist therefore, and only when the use thereof is intended for profit is it required that prior approval of the government agency or office wherein the work is created shall be necessary. Consequently, all the other uses to which the work of the government may be subjected to, not involving use for profit, may be legally done. These uses applicable to both the unprotected subject matter, or official text of a legislative, administrative or legal nature, as well as any official translation thereof, and works of the government, are embraced under the provisions of the law touching on the economic rights of an author. Simply put, these uses may be done by a person to public domain works even if the latter is not the author of such work. This is the practical effect of non-recognition of copyright on the works of the government and pertinent unprotected subject matter ( Tolentino, 2008).

III . Issues and Concerns in Exploitation of Works of Government

1. Posting of government works in websites

There are international moves to improve access to government material. In December 2003, the UN convention in Geneva- all stakeholders should work together to improve access to information and knowledge. This commitment by the UN and participating countries (including Australia) to build an info society with greater access to a public domain is particularly relevant. In May 2001, the European Council and Commission adopted a Regulation on public access to European Parliament, Council and Commission documents. In 2003, the European commission Directive was issued to facilitate the re use of public sector of info held by public sector bodies of member states. The Directive is expressed not to affect the IPR of the public sector bodies. Over the last few years, increasing call for open access to research studies, particularly scientific studies. Professor Fitzgerald said that the copyright becomes the key tool in managing downstream usage –open or close (www.ag.gov.an).

The copyright implication of posting papers of NIH to PubMed Central (PMC ) was raised specifically on how the inappropriate posting without permission will be avoided .

NIH manuscript submission system is the only way in which authors may deposit manuscripts to PMC. It is alos the duty of PMc to require the author to conform, he or she has the right or permission to post the manuscript submitted. NIH is also concerned on how to safeguard copyrighted material once posted. PMC has algorithms to detect inappropriate use, such as bulk downloading and sites responsible for inappropriate use are warned of the consequences of violating copyright provisions and blocked from further access. PMC deposition requirement does not undermine copyright protection of the grantee’s work. Copyrights on works displayed in PMC are fully enforceable by the copyright owners. Art. 2(1) of the Berne Convention is consistent with the widespread practice of reservation of rights in works by the funders of those works.

Concern about public access policy and potential conflict with Article 13 of the WTO TRIPS is unwarranted because the requirement does not interfere with the author’s commercial use of the work. Article 13 directs member countries to confine limitations on exclusive rights to special cases that do not conflict with the normal exploitation of the work. But the deposition, requirement makes no limitation on the exclusive rights attached to the work. It merely requires the right to display author’s manuscript on PMC.

A report on Copyright Law and Intellectual Property by Fitzgerald and Pappalando submitted in December 2009 stressed on the need for the government’s exercise of copyright should be consistent with the policy on open access to and reuse of public sector information (PSI) (www. gc.ca). It was also recommended to adopt copyright management practices appropriate to web2.0 and beyond environment; .statements of user;’ rights should be clearly stated; use of simple, standardized , automatic licenses covering uses and reuse PSI; support and guidance for agencies using open contact (public license like Creative Commons); remove copyright barriers to archival and cultural materials; classify meaning of publication to give certainty to the duration of copyright and avoid impracticality and set statutory limits to copyright protection for unpublished works and ensure access to legal advice and guidelines about copyright law and practice.

2. Use of Works Produced by Government

In Singapore, street map producer Virtual Map(VM) lost a court battle on august 6,2007 after the Singapore Land Authority (SLS) sued it for copyright infringement of SLA’s maps .The material in question is the data needed to make maps of Singapore streets which the SLA licensed to VM but whose license terminated in July 2002. Notwithstanding, VM continued to sell and distribute its maps. It also created new maps with the SLA alleged were reproductions of the authority’s works. The SLA sought damages and an injunction to restrain VM from further infringement of the obtained data.

No express provision of the US Copyright Act similarly consigns to the public domain works prepared by employees of state and local governments .The nature and range of state materials that are to be analogized to legislation and court decisions. The Court of Appeals of Second circuit 132 official county tax maps-not automatically stripped of copyright simply because they are authored by county officials and because they are used as a basis for the assessment of property taxes.

The Court held that the taxing statue affords the public adequate notice of their obligation, so that state ownership of the maps would create the problems of due process and if rewarded so that further evidence could be presented on the issue of the country’s need for copyright as a financial incentive for its mapmaking activity.

The question as to whether privately authorized codes- building and fire codes- even model laws that are written (often simply by reference by a legislation body say in a county or town are protected by copyright is settled by the Court of Appeals for the 5th Circuit concluded in 2002 that such privately drafted codes are protected by copyright at the outset-they are thrust into the public domain when they are adopted by a town as its authorization legal text –at least when such adoption is actually sought by the drafting body.

The Banks vs. Manchester case concluded that a denial of copyright would pose a threat to the useful provision of such codes to busy and under funded municipal entities. The Red Book of the National Automobile Dealing Association though made reference by a State for insurance purposes has not lost its copyright.

3. Moral Rights in Works of Government

The South Australian Attorney-General’s Response to Copyright Law Review Committee

“Crown Copyright” Issues Paper (February 2004) raised the issue as to whether moral rights should apply in the context of copyright.

Moral rights are a relatively new concept in Australian intellectual property law. As moral rights are personal and non-assignable, they cannot attach to the Crown itself.

In the context of Crown copyright, it is considered that either: moral rights should not apply, or moral rights of work created in the course of employment should be able to be waived as an incident of the contract of employment.

It could be argued that moral rights should not apply automatically to any material created during the course of employment. An author who creates material on behalf of, or at the request of, their employer during the course of their employment, is not necessarily producing the work on their own behalf, or to convey their own ideas. This argument applies equally to works of government employees. In this regard, it is submitted that a distinction be drawn between commercial work and creative work. For example, in the case of material that is generally considered to be creative work, eg. commissioned paintings, there is a stronger claim that moral rights should apply, whether or not the work is created in the course of the creator’s employment.

The existence of moral rights in the context of copyright raises particular problems. For example: if a ministerial adviser writes part of a Minister’s speech or judge’s associate writes part of a judgment, the right of attribution of authorship may mean that the writer could enforce their moral right to be represented as the author of the work. The right of integrity of authorship may mean that it is more difficult to alter material and to adapt to different uses, eg. to change part of a computer program’s code to suit a new use.

Accordingly, it may be argued that moral rights should not apply in the context of Crown copyright on the ground that an author seeking to enforce such moral rights might impede peace, order and good by seeking injunctions, declarations or damages against the government.(www.ag.gov.au)

Moral rights are personal and non-assignable –cannot attach to the government. Moral rights of government employees over work created in the course of employment should be waived as an incident of the contract of employment. It could be argued that moral rights should not apply automatically to any material created during the course of employment. An author who creates material on behalf or at the request of their employer during the course of their employment is not necessarily producing the work on their behalf or to convey their own ideas. This argument applies equally to government employees. A distinction then has to be made if the work is a commercial or a creative work. If the work is creative, then there should be a stronger claim for moral rights.

The author seeking to enforce moral rights might impede peace, order and good government by seeking injunction, declaratory relief and damages against government.

Although right is personal to the author, in the relationship between employer and employee, Israeli law is unclear as to whether the employees’ moral rights in the work created by him for his employer are retained by the employee or the employer. Prof. J.Weissman, relying on the personal character of the right and the Model Law published by UNESCO and WIPO, sees towo alternatives- wither the rights are retained by the employee or the employee is deemed to waive (www.itpolicy.gov).

Under Philippine copyright law, moral rights are relatively expansive on the behalf of the copyright holder, which are listed below:

Attribution

  • The right to be prominently displayed as the creator of the copyrighted material, in any form practical to the work
  • The right to change or even withhold the work from circulation

Integrity of ownership

  • The right to object to any alteration detrimental to the name of the creator of the material
  • The right to restraining the use of the creator’s name in a work not of his making

Copyright holders are not allowed to be forced to create or publish his or her works already published, as that could be classified as a breach of contract. However, the copyright holder could also be held liable for breach of contract.

The Intellectual Property Code also permits the waiver of moral rights in most cases, but does not allow it if the following situations occur:

  • If the creator’s name will be used to damage the reputation of another person
  • If the creator’s name will be used to give credit to something he or she did not make

Moral rights are automatically waived in collective works unless the copyright holders expressly reserve their moral rights. Also, if no objections have been made during the time a copyright holder waives his or her moral rights or even if moral rights were waived unconditionally, works altered or even destroyed would not constitute as a violation of moral rights.

In the Philippines, the term of moral rights, unless they were waived, is the same as the term of copyright of a literary work (lifetime plus 50 years). Violation of moral rights may also be contested as a violation of the Civil Code. Any damages collected under the Civil Code shall be given to the copyright holder, or if the holder is already dead, be put in a trust account to be given to the copyright holder’s heirs. If the heirs defaulted, the damages go to the government.

The works of the Government, its officers and employees in any of its subdivisions and instrumentalities including the Government Owned and Controlled Corporation in lieu of their public duties are not copyrightable. However, even if Government works are not protected by Copyright Law, it is also inevitable to secure its prior consent before exploiting their work. Absent this consent is vital in claiming right over the exploited work. The government is not without any right over its works, under the law, it is entitled to royalty. Hence, consent is indispensable requisite before using a copyright protected work or in making a derivative work deriving from an original work (Ola, 2008).

4. Copyright like Methods and Motives for government Controls and Information

The Syracuse Law Review 1995 mentions of the Methods and Motives for government controls on information in the form of Copyright Like Methods of Agency Information Control: Regulating Use Thru License Agreements and Royalties; Limiting Access to Selected Recipients; Denying or Relaying Access to Digital Versions of Public Data; Agreeing to Restrict Disclosure of Digital Data; Restricting Use thru Contracts

The motives for controlling information include data integrity, revenues to support info services and general revenue raising.

Government’s ability to copyright information can be used to control or affect the flow of official information, punish those who infringe on copyright and accomplish or justify other objectives –political or otherwise –unrelated to a specific use of information.

V. Conclusion

Copyright on Works of government varies from one country to another. Thus, it is imperative that one is able to distinguish the prevailing copyright laws in the country under review.

This distinction is not only relevant in terms of acquisition of jurisdiction but may also be important in what constitutes infringement and the available remedies. It is equally important to apply the concept of fair use and the validity of agreements on assignment and transfer of copyrights in favor of the government or the employee in dealing with copyright of government works. The Philippine Copyright Law is relatively young compared to those of the selected countries. Much is left to be done not only in the scrutiny and possible amendments of the existing provisions but also on the implementation aspect.

Certain copyright like provisions on works of government can also be established not only to preserve the integrity of the government records and publications but also to protect employees from undue commercial exploitation of their works. If it is the mandate of the government to provide the public access to its data/information ,it is also incumbent upon it to establish certain safety nets on how to secure and protect its own interest.

The nature of employment as well the purpose of the work may draw the line on what is protected or not among works of government. It is equally important to consider not only the economic but also the moral rights of government employees should the work be covered by copyright protection.

The era of digitization has prompted various countries to amend copyright laws. This is seemingly in response not only to the convenience and cost –efficiency associated with technology but also of the economic gains derived from it. Policies on access to and open re-use have been recommended to be compatible with existing copyright laws although certain parameters in the form of reservation clauses, terms and conditions of use or users’ rights in web- based dissemination of information have to be in place in order to preserve the copyright of the government and its employees .


References:

  • Tolentino, Paolo Carlo C .Public Domain Works: The Government’s Role in Securing Public Use Thereof, December 2008.
  • Ola, Winnie Fred. The Scope of “Educational Purpose” to Qualify as Exceptions in Limitations on Copyright, Decmeber 2008.
  • Fitzgerald and Pappalando.Report on Copyright Law and Intellectual Propery. December 2009.
  • South Australian Attorney-General’s Response to Copyright Law Review Committee .“Crown Copyright” Issues Paper .February 2004.
  • Twin evils : Government Coppyright and Copyrightlike Controls Over Government Information : Syracuse Law Review 1995 ADA 394923
  • Jack B. Pfeiffer vs. Central Intelligence Agency, et al, USA ,District of Columbia Commission, August 1,1995.
  • Intellectual Property Code of the Philippines
  • Wikipedia,the Free Encyclopedia,en. Wikipedia.org/wiki/copyright, retrieved March 6,2010.
  • wikimedia.org retrieved April 3,2010
  • http://www.cendi .gov/publications retrieved April 3,2010.
  • wais.access.gpo.gs retrieved April 9,2010
  • www. cic.gc.ca retrieved April l 9, 2010
  • ww.ag.gov.au retrieved April 11,2010
  • freegovinfo.info/copyright retrieved April 11,2010
  • dtic.mil retrieved April 11,2010
  • http:// gov2.net.au retrieved April 11,2010
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