[DMCA-Activists] Geist: Piercing "P2P" Myths

[Seth Johnson]

> http://firstmonday.org/issues/issue10_4/geist/


Piercing the peer–to–peer myths: An examination of the Canadian
experience

by Michael Geist


Abstract

Canada is in the midst of a contentious copyright reform with
advocates for stronger copyright protection maintaining that the
Internet has led to widespread infringement that has harmed the
economic interests of Canadian artists. The Canadian Recording
Industry Association (CRIA) has emerged as the leading proponent
of copyright reform, claiming that peer–to–peer file sharing has
led to billions in lost sales in Canada.

This article examines CRIA’s claims by conducting an analysis of
industry figures. It concludes that loss claims have been greatly
exaggerated and challenges the contention that recent sales
declines are primarily attributable to file–sharing activities.
Moreover, the article assesses the financial impact of declining
sales on Canadian artists, concluding that revenue collected
through a private copying levy system already adequately
compensates Canadian artists for the private copying that occurs
on peer–to–peer networks.

--

The Canadian government has been the target of intense lobbying
for stronger copyright legislation in recent months. Led by the
music industry, which claims that it has experienced significant
financial losses due to music downloading, the campaign
culminated in November 2004 with a lobby day on Parliament Hill
[1].

The campaign is premised on three key pillars. First, that the
Canadian recording industry has sustained significant financial
losses in recent years due to decreased music sales. Second, that
those losses can be attributed to peer–to–peer file sharing.
Third, that the losses have materially harmed Canadian artists.

The time has come to acknowledge that each of these pillars is a
myth.

In speaking with Canadian government leaders, the industry played
a familiar tune. Graham Henderson, president of the Canadian
Recording Industry Association (CRIA), argued that music
downloading has devastated the industry. While Canadian rock star
Tom Cochrane indicated that he was uncomfortable suing individual
file sharers, he nevertheless characterized Canada’s laws as akin
to those found in third world countries [2].

Amid the claims of industry losses, the industry failed to make
the case that music downloading is significantly harmful to
Canadian artists.

Amid the claims of industry losses, the industry failed to make
the case that music downloading is significantly harmful to
Canadian artists. Even Jim Cuddy, lead singer for the group Blue
Rodeo, acknowledged that it was hard to determine whether music
downloading has actually hurt his band [3]. In fact, a careful
examination of CRIA’s own numbers suggests that the financial
impact of music downloading on Canadian artists is greatly
exaggerated.

The actual financial impact of music downloading has long been
difficult to ascertain. In August 2003, CRIA issued a press
release claiming C$250 million in losses over the previous three
years [4]. Three months later, another press release claimed
C$425 million in losses [5]. Just weeks before the lobby day,
CRIA General Counsel Richard Pfohl told a university audience
that the figure was actually C$450 million per year since 1999,
totaling roughly C$2 billion over the past five years [6].

 
Year    Million (C$)
1999    699.9
2000    690.3
2001    645.8
2002    609.5
2003    559.7
2004    562.2

Table 1: Canadian CD sales (Source: CRIA).

In fact, the guesswork surrounding record sales is unnecessary
since CRIA posts its members’ monthly record sales data directly
on its Web site. According to CRIA, Canadian CD sales in 1999
generated C$699.9 million. That figured declined annually to
C$690.3 million (2000), C$645.8 million (2001), C$609.5 million
(2002), and C$559.7 million (2003). In 2004, sales increased to
C$562.2 million. Using CRIA’s own numbers and 1999 as a
benchmark, the cumulative decline in CD sales revenue in Canada
is C$431.7 million. Given that total CD sales revenues during the
period totaled C$3.7 billion, the percentage decline is a
relatively modest 8.6 percent [7]. While a C$431.7 million
decline over a six–year period may still hurt, the source of that
decline must also be examined. The financial impact of
file–sharing is uncertain since the losses tied to file–sharing
are only those that displace a potential sale, not all downloads.
Those losses must be offset against downloads of music that (i)
involve sampling before purchasing; (ii) that are no longer for
sale; (iii) that are in the public domain or available with the
express permission of the copyright holder; and, (iv) that are
compensated in Canada through the private copying levy.
Although loath to discuss the matter publicly, according to an
October 2004 Economist article, an internal music label study
found that between 2/3 and 3/4 of recent sales declines had
nothing to do with Internet music downloads.

Although the music industry seems loath to discuss the matter
publicly, according to an October 2004 Economist article, an
internal music label study found that between 2/3 and 3/4 of
recent sales declines had nothing to do with Internet music
downloads [8]. That finding was echoed in a Ministry of Canadian
Heritage commissioned report which concluded that

    "[t]he assumption by the recording industry that demand for
CDs is fundamentally strong and that Internet piracy is to blame
for falling sales is a simplistic reaction to a complex problem
... to place the burden wholly or partly on illegal downloads
from the Internet is to ignore a host of other reasons." [9]

The "other reasons" include the growth of DVD sales, which
accounted for zero revenue in 1999, but generated over C$170
million in new revenue from 2000–2004 [10]. The popularity of
DVDs is surely related to the decline in CD sales and the
shrinking shelf space allocated to CDs by music retailers.

Moreover, U.S. census data actually indicates that the number of
hours people spend listening to music is declining. Its data
suggests that people now spend increasing amounts of time talking
on cellphones, playing videogames, watching movies and using the
Internet [11].

The shift in music retail merchandising and marketing has also
had an enormous impact on CD sales. The Recording Industry
Association of America, CRIA’s U.S. counterpart, reports that the
dominant retail chains are now big–box retailers such as
Wal–Mart. In Canada, Wal–Mart and Costco now account for 25
percent of the music retail marketplace, while in the U.S.,
Wal–Mart, Target and BestBuy are responsible for over half of all
CDs sold [12].

This shift affects the music industry in two ways. First, while
traditional record stores carry 60,000 or more titles, Wal–Mart
stores focus primarily on new releases, featuring an average of
5,000 titles [13]. The decreasing availability of older titles
hurts an industry that has traditionally depended upon catalogue
sales for about 40 percent of its retail music revenue [14].

Second, Wal–Mart has placed new pressures on the retail pricing
of CDs — capping retail pricing in the United States at US$9.72
per CD. The pricing pressure has had a dramatic impact on the
revenue generated from each CD sale. According to CRIA’s own
numbers, revenue from prices of an average CD in 2004 was
C$10.95, down 8.8 percent from C$12.00 per CD in 1999. The bottom
line impact has been to shave C$53.9 million in revenue for sales
in 2004 when compared with the same unit sales in 1999.

Additional factors behind the decreased revenues include a
significant decline in the number of new releases issued over the
past six years (less product presumably results in fewer sales)
[15] and the view that the CD sales decline simply reflects
broader economic conditions. For example, during the 1991
economic recession, CD sales growth in the United States dropped
by 11 percent, a sharper drop than the most recent downturn [16].

In fact, perhaps the best evidence yet of the tenuous link
between file–sharing and music sales comes from the music
industry’s performance following the March 2004 Federal Court of
Canada’s file–sharing decision which denied CRIA’s demand to
disclose the identities of 29 alleged file sharers [17]. Despite
the dire predictions that the decision would decimate music
sales, the six–month period following the decision saw CD unit
sales jump by 12.4 percent in Canada over the prior year [18].

The good news does not end with rising music sales in Canada. The
evidence suggests that Canadian artists have scarcely been harmed
by the reduced sales from 1999 to 2004 since royalty losses are
fully compensated through the private copying levy.

To understand the impact of declining sales on Canadian recording
artists, three pieces of information are needed. First, the
percentage of the Canadian retail music market commanded by
Canadian artists must be identified in order to determine lost
Canadian artist sales. Let us assume that the percentage in music
download practices mirror retail purchasing habits.

Statistics Canada, the government’s statistical agency, has
estimated that Canadian artists account for roughly 16 percent of
the Canadian market [19], while the Canadian music industry
claims that the number is actually 23 percent [20]. Using the
higher 23 percent figure, this suggests that the total six year
sales loss for Canadian artists is C$99.3 million or C$16.5
million per year.

Note, however, that the C$16.5 million annual figure reflects the
total lost Canadian artist sales, not the lost Canadian artist
sales attributable to music downloading. If the various other
factors contributing to the loss discussed earlier are included
and the Economist’s estimate 66 percent of recent sales declines
had nothing to do with Internet music downloads (the high end of
the estimate), then the loss in Canadian artist sales that could
be due to music downloading would stand at C$5.5 million per
year.

The second key piece of information is the royalty rate earned by
Canadian artists for their music sales. Even if Canadian artist
sales are down by C$5.5 million per year due to music
downloading, the actual loss sustained by the artists is limited
to the lost royalties attached to those sales.

Although royalty rates vary between artists, the consensus
estimate is that the combined royalties earned by both the
performer and the songwriter stand at approximately 12 percent.
In fact, Sanderson Taylor, a leading Canadian music law firm,
maintains that the actual royalty earned by the artists is
typically even lower, since the producer’s royalty is taken from
the artists’ compensation and many contracts do not provide for a
full royalty for CD sales [21].

Assuming artists receive the full 12 percent royalty, the annual
royalty loss attributable to music downloading in Canada is about
C$655,000 (12 percent of C$5.5 million). For those that claim
that the full industry loss should be counted, the annual lost
royalty for Canadian artists stands at C$2 million.

Some in the industry argue that this understates the impact since
CRIA’s financial data reflects wholesale shipments and revenues,
rather than the somewhat higher revenues generated at the retail
level. According to CRIA’s president Graham Henderson, the
artists’ royalty may be as high as twenty percent of the
wholesale CD pricing [22]. Even with the higher royalty figure,
the annual lost royalty for Canadian artists could only increase
to C$1.1 million for lost sales due to file–sharing or C$3.3
million for all decreased sales.

Given the tens of millions of dollars that the Canadian
government spends annually to support the creation of Canadian
music, it is apparent that the relative impact of lost royalties
due to file sharing pales by comparison.

Given the tens of millions of dollars that the Canadian
government spends annually to support the creation of Canadian
music [23], it is apparent that the relative impact of lost
royalties due to file–sharing pales by comparison.

Moreover, lost royalties must be offset by the third key factor
used to calculate the impact of music downloading on Canadian
artists — the private copying levy.

The levy represents an effective, if controversial, means to
compensate artists. The Copyright Act includes a private copying
exception that grants Canadians the right to make personal,
non–commercial copies of music without requiring permission from
the copyright holder. Both the Copyright Board of Canada and the
Federal Court of Canada have ruled that private copying may
include peer–to–peer music downloads [24]. This interpretation is
consistent with both the technologically neutral language found
in the legislation as well as with many similar private copying
systems in Europe.

In return for that right, the Copyright Board of Canada
establishes a levy on blank media such as recordable CDs and on
equipment such as MP3 players. The Canadian Private Copying
Collective (CPCC) collects the levy and is responsible for
distributing the proceeds to songwriters, performers, and the
music labels.

While artists may only receive a few pennies per blank CD, those
pennies add up to millions of dollars. As of the end of 2004, the
CPCC has collected just over C$120 million since 1999 (the levy
generated C$33.2 million in 2004) [25], though the collective has
been agonizingly slow in distributing the proceeds [26].

The allocation of the collected funds among songwriters,
performers, and the labels varies from year to year. For 2004,
the Copyright Board determined that 66 percent of the funds would
be distributed to songwriters through their collectives (Society
of Composers, Authors and Music Publishers of Canada, Canadian
Musical Reproduction Rights Agency, and Society for Reproduction
Rights of Authors, Composers and Publishers in Canada), 18.9
percent would be distributed to performers through their
collectives (Neighbouring Rights Collective of Canada (NRCC) and
Société de gestion des droits des artistes–musiciens), and 15.1
percent would be distributed to the labels through the NRCC
collective [27]. It is important to note that the funds earmarked
for songwriters are distributed worldwide, while the performer
and label compensation are available only to Canadians.

Although identifying the precise compensation earned by Canadian
artists under the levy is difficult, there is no question that
the sum is in the millions of dollars annually. For example, the
18.9 percent earned by Canadian performers generated over C$5
million in 2004. Considering that the Canadian royalty loss for
all lost sales is no more than C$2 million annually, it is
apparent that the private copying levy, once distributed,
provides Canadian artists with more than adequate compensation
for their losses due to copying that occurs on peer–to–peer
systems.

Not only does the private copying levy as it is currently
designed provide Canadian artists with full compensation for
their losses due to music downloading, but the structure of the
Canadian music business further insulates the impact felt by
Canadian artists.

Although CRIA accounts (by its own estimate) for 95 percent of
the sound recordings manufactured and sold in Canada, the vast
majority of Canadian artists actually get their start with
smaller, independent labels [28]. In fact, Applaud!, a leading
Canadian music industry publication, recently concluded that
"it’s the independent companies which continue to take the lead
in developing new talent, and which can proudly boast that their
under–the–radar success is building the careers of young Canadian
artists on an international basis" [29],

Moreover, many independent music labels and artists welcome music
downloading as an opportunity, not a threat. Neil Leyton, founder
of Fading Ways Music, a Toronto–area independent label, is a
strong supporter of music downloading, having found that it is a
great method of promotion that ultimately increases sales [30].
Similarly, Bob Wiseman, an original member of Blue Rodeo, has
expressed his support for peer–to–peer distribution and his
disagreement with his former bandmate Jim Cuddy [31].

--

Conclusion

Following years of lobbying by CRIA, a new reality is only now
coming to light — music downloading is not responsible for the
ills of the music industry and Canadian artists have not been
harmed by the sales declines that have occurred over the past
five years. Although faced with significant pressure to reform
Canadian copyright law, it is increasingly apparent that the
industry’s ills are not the result of peer–to–peer downloading.
Moreover, the Canadian experience with private copying suggests
that a levy system may provide an effective alternative to
adequately compensate artists for lost royalties that may occur
due to the current popularity of file sharing services. End of
article

 
About the author

Michael Geist is the Canada Research Chair of Internet and
E–commerce Law at the University of Ottawa. He has obtained a
Bachelor of Laws (LL.B.) degree from Osgoode Hall Law School in
Toronto, Master of Laws (LL.M.) degrees from Cambridge University
in the U.K. and Columbia Law School in New York, and a Doctorate
in Law (J.S.D.) from Columbia Law School. Dr. Geist has written
numerous academic articles and government reports on the Internet
and law, is a member of Canada’s National Task Force on Spam, is
columnist on technology law issues for the Toronto Star and
Ottawa Citizen, and is the author of the textbook Internet Law in
Canada (Captus Press) which is now in its third edition. More
information can be obtained at http://www.michaelgeist.ca.

 
Acknowledgments

The opinions expressed herein are personal and do not necessarily
reflect the views of the University of Ottawa. An earlier version
of this article appeared in the Toronto Star in two parts on 29
November 2004 and 6 December 2004.

Direct comments to: mgeist [at] pobox [dot] com.

 
Notes

1. CTV.ca News Staff, 2004. "Musicians Call for an Update on
copyright law," at
http://www.ctv.ca/servlet/ArticleNews/story/CTVNews/1101331178030_15?hub=Canada,
accessed 23 March 2005.

2. Ibid.

3. Robert Thompson, 2004. "Rockers sing the copyright blues:
Demand Ottawa toughen law to halt downloading," National Post (25
November 2004).

4. Canadian Recording Industry Association, (CRIA), 2003.
"Canadian record industry initiates second phase of education
program with users of file–sharing services," at
http://www.cria.ca/news/140803_n.php, accessed 23 March 2005.

5. CRIA, 2003. "The Canadian recording industry condemns
government inaction on copyright," at
http://www.cria.ca/news/061203_n.php, accessed 23 March 2005.

6. University of Windsor, Faculty of Law, 2004. "Rocking in the
Not So Free Virtual World Conference," at
http://cfl-x.uwindsor.ca/LAW/conference01.htm, accessed 23 March
2005.

7. All CRIA industry statistics online at
http://www.cria.ca/stats.php.

8. The Economist, 2004. "Music’s Bright Future" (28 October
2004), at
http://www.economist.com/displaystory.cfm?story_id=S%27%29%28%20%2ERA%3F%25%23P%20T%0A,
accessed 23 March 2005 (subscription required).

9. Cathy Allison, 2004. "The Challenges and Opportunities of
Online Music: Technology Measures, Business Models, Stakeholder
Impact and Emerging Trends," Report for Canadian Heritage, p. 73,
at
http://www.canadianheritage.gc.ca/progs/ac-ca/progs/pda-cpb/pubs/online_music/online_music_e.pdf,
accessed 23 March 2005.

10. CRIA, 2000–2003. Statistics archives at
http://www.cria.ca/stats.php#archives, accessed 23 March 2005.

11. United States Census Bureau, 2003. "Service Annual Survey,
Information Services Sector," p. 6, at
http://www.census.gov/prod/2003pubs/02statab/infocom.pdf,
accessed 24 March 2005.

12. Warren Cohen, 2004. "Wal–Mart Wants $10 CDs," Rolling Stone
(12 October 2004), at
http://www.rollingstone.com/news/story/_/id/6558540/thekillers?pageid=rs.Home&pageregion=single1&rnd=1097616001120&has-player=unknown,
accessed 29 March 2005.

13. Ibid.

14. Ibid.

15. James K. Wilcox, 2003. "Where Have All the CDs Gone?" Sound &
Vision Online (June 2003), at
http://www.soundandvisionmag.com/article.asp?section_id=2&article_id=453,
accessed 29 March 2005.

16. Ibid.

17. BMG Canada Inc. v. John Doe (F.C.), [2004] 3 F.C. 241, 2004
FC 488, at http://www.canlii.org/ca/cas/fct/2004/2004fc488.html,
accessed 24 March 2005. For commentary on this decision, please
see: John Borland, "Judge: File sharing legal in Canada," at
http://news.com.com/2100-1027_3-5182641.html, accessed 24 March
2005; "Music industry loses in downloading case," at
http://www.ctv.ca/servlet/ArticleNews/story/CTVNews/1080754657038_76163857///?hub=TopStories,
accessed 24 March 2005;
http://www.cbc.ca/MRL/clips/ram-lo/fung_onlinemusic0403311.ram.

18. CRIA, 2003. Statistics archives, at
http://www.cria.ca/stats.php#archives, accessed 23 March 2005.

19. Statistics Canada, 2003. "The Daily: Sound Recording" (7 July
2003), at
http://www.statcan.ca/Daily/English/030707/d030707b.htm, accessed
24 March 2005.

20. Music in Canada Coalition press release (24 November 2004)
(on file with the author).

21. Chris Taylor, 2004. "Where The Money Goes," at
http://www.sandersontaylor.com/dazzub-load.php?id=17#03, accessed
28 March 2005.

22. CRIA’s President Responds to Editorial in Northern News (9
March 2005), at http://www.cria.ca/news/100305_n.php, accessed 30
March 2005.

23. SaveCanadianMusic.com, at
http://www.savecanadianmusic.com/main.php, accessed 30 March
2005.

24. Copyright Board of Canada, 2003. Copyright Board’s Private
Copying 2003–2004 Decision (12 December 2003), at
http://www.cb-cda.gc.ca/decisions/c12122003-b.pdf, accessed 28
March 2005; and BMG Canada Inc. v. John Doe (F.C.), [2004] 3 F.C.
241, 2004 FC 488, at
http://www.canlii.org/ca/cas/fct/2004/2004fc488.html, accessed 28
March 2005.

25. Canadian Private Copying Collective, 2005. "$33.2 million
distributed to rights holders in recorded music," (7 January
2005) at http://cpcc.ca/english/pdf/CPCC07Jan05.pdf.

26. Ibid.

27. Copyright Board of Canada, 2003. "Tariff of Levies to be
Collected by CPCC in 2003 and 2004 on the Sale, in Canada, of
Blank Audio Recording Media," (13 December 2003) at
http://www.cb-cda.gc.ca/tariffs/certified/c13122003-b.pdf,
accessed 28 March 2005.

28. Canadian Heritage, 2004. "Fact Sheet: Canada’s Sound
Recording Industry," at
http://www.pch.gc.ca/special/tomorrowstartstoday/en-back-2001-06-26-fs1.html,
accessed 28 March 2005.

29. Richard Flohil, 2004. "Canada’s Hottest independent Record
Companies Develop New International Talent," Applaud! volume 2,
number 13 (November 2004), at 1.

30. E–mail on file with author.

31. E–mail on file with author.

 
References

Cathy Allison, 2004. "The Challenges and Opportunities of Online
Music: Technology Measures, Business Models, Stakeholder Impact
and Emerging Trends," Report for Canadian Heritage, p. 73, at
http://www.canadianheritage.gc.ca/progs/ac-ca/progs/pda-cpb/pubs/online_music/online_music_e.pdf,
accessed 23 March 2005.

BMG Canada Inc. v. John Doe (F.C.), [2004] 3 F.C. 241, 2004 FC
488, at http://www.canlii.org/ca/cas/fct/2004/2004fc488.html,
accessed 28 March 2005.

John Borland, "Judge: File sharing legal in Canada," at
http://news.com.com/2100-1027_3-5182641.html, accessed 24 March
2005.

Canadian Heritage, 2004. "Fact Sheet: Canada’s Sound Recording
Industry," at
http://www.pch.gc.ca/special/tomorrowstartstoday/en-back-2001-06-26-fs1.html,
accessed 28 March 2005.

Canadian Private Copying Collective, 2005. "$33.2 million
distributed to rights holders in recorded music," (7 January
2005) at http://cpcc.ca/english/pdf/CPCC07Jan05.pdf.

Canadian Recording Industry Association (CRIA), 2003. "Canadian
record industry initiates second phase of education program with
users of file–sharing services," at
http://www.cria.ca/news/140803_n.php, accessed 23 March 2005.

CRIA, 2003. Statistics archives, at
http://www.cria.ca/stats.php#archives, accessed 23 March 2005.

Warren Cohen, 2004. "Wal–Mart Wants $10 CDs," Rolling Stone (12
October 2004), at
http://www.rollingstone.com/news/story/_/id/6558540/thekillers?pageid=rs.Home&pageregion=single1&rnd=1097616001120&has-player=unknown,
accessed 29 March 2005.

Copyright Board of Canada, 2003. Copyright Board’s Private
Copying 2003–2004 Decision (12 December 2003), at
http://www.cb-cda.gc.ca/decisions/c12122003-b.pdf, accessed 28
March 2005.

Copyright Board of Canada, 2003. "Tariff of Levies to be
Collected by CPCC in 2003 and 2004 on the Sale, in Canada, of
Blank Audio Recording Media," (13 December 2003), at
http://www.cb-cda.gc.ca/tariffs/certified/c13122003-b.pdf,
accessed 28 March 2005.

CTV.ca News Staff, 2004. "Music industry loses in downloading
case," at
http://www.ctv.ca/servlet/ArticleNews/story/CTVNews/1080754657038_76163857///?hub=TopStories,
accessed 24 March 2005;

CTV.ca News Staff, 2004. "Musicians Call for an Update on
copyright law," at
http://www.ctv.ca/servlet/ArticleNews/story/CTVNews/1101331178030_15?hub=Canada,
accessed 23 March 2005.

The Economist, 2004. "Music’s Bright Future," (28 October 2004),
at
http://www.economist.com/displaystory.cfm?story_id=S%27%29%28%20%2ERA%3F%25%23P%20T%0A,
accessed 23 March 2005 (subscription required).

Richard Flohil, 2004. "Canada’s Hottest independent Record
Companies Develop New International Talent," Applaud!, volume 2,
number 13 (November 2004), at 1.

Statistics Canada, 2003. "The Daily: Sound Recording" (7 July
2003) at,
http://www.statcan.ca/Daily/English/030707/d030707b.htm, accessed
24 March 2005.

Chris Taylor, 2004. "Record Producer Agreements," at
http://www.sandersontaylor.com/article-load.php?id=t4, accessed
28 March 2005.

Robert Thompson, 2004. "Rockers sing the copyright blues: Demand
Ottawa toughen law to halt downloading," National Post (25
November 2004).

U.S. Census Bureau, 2003. "Service Annual Survey, Information
Services Sector," p. 6, at
http://www.census.gov/prod/2003pubs/02statab/infocom.pdf,
accessed 24 March 2005.

University of Windsor, Faculty of Law, 2004. "Rocking in the Not
So Free Virtual World Conference," at
http://cfl-x.uwindsor.ca/LAW/conference01.htm, accessed 23 March
2005.

James K. Wilcox, 2003. "Where Have All the CDs Gone?" Sound &
Vision Online (June 2003), at
http://www.soundandvisionmag.com/article.asp?section_id=2&article_id=453,
accessed 29 March 2005.
Editorial history

Paper received 3 April 2005; accepted 5 April 2005.
HTML markup: Susan Bochenski and Edward J. Valauskas; Editors:
Mary Minow and Edward J. Valauskas.

Contents Index

Creative Commons License
This work is licensed under a Creative Commons License.

Piercing the peer–to–peer myths: An examination of the Canadian
experience by Michael Geist
First Monday, volume 10, number 4 (April 2005),
URL: http://firstmonday.org/issues/issue10_4/geist/index.html