Independent Telecommunications Providers Association (ITPA)

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Jonathan L. Holmes Executive Director regulatory@itpa.ca

31 May 2021

By Email copyright-consultation-droitdauter@canada.ca

Subject: Submission to Innovation, Science and Economic Development Canada regarding the Consultation on a Modern Copyright Framework for Online Intermediaries

  1. The Independent Telecommunications Providers Association (“the ITPA”) is pleased to file these comments on the behalf of its twenty-one member companies. A list of ITPA members can be found in the Appendix to these comments. ITPA members are rural Internet Service Providers (“ISPs”) and as such are intermediaries that provide their customers with access to the Internet.Footnote 1
  2. The ITPA has had the opportunity to review in advance the joint comments of Bell Canada, the Canadian Communications Systems Alliance (“the CCSA”), Cogeco Communications, Eastlink, Quebecor Media, Rogers Communications, SaskTel, Shaw Communications and TELUS Communications. It has also had the opportunity to review in advance the separate additional comments filed by the CCSA.
  3. The ITPA supports the joint comments of the service providers identified above regarding safe harbours and establishing a procedure for applying for injunctive relief. The ITPA takes no position on the collective licencing issue.
  4. The ITPA also supports the separate additional comments by filed by the CCSA and its focus on the concerns of smaller, independent ISPs. Here too, the ITPA takes no position on the collective licencing regime.
  5. All of which is respectfully submitted.

Yours truly,

Jonathan L. Holmes

Appendix

Independent Telecommunications Providers Association Members

  • 9315-1884 Québec inc.
  • Brooke Telecom Co-operative Limited
  • Bruce Telecom
  • City West Cable & Telephone Corp.
  • Cochrane Telecom Services
  • CoopTel
  • Execulink Telecom Inc.
  • Gosfield North Communications Co-operative Limited
  • Hay Communications Co-operative Limited
  • Huron Telecommunications Co-operative Limited
  • The Lansdowne Rural Telephone Company Limited
  • Mornington Communications Co-operative Limited
  • Nexicom Inc.
  • North Frontenac Telephone Corporation Limited
  • North Renfrew Telephone Company Limited
  • Quadro Communications Co-operative Inc.
  • Roxborough Telephone Company Limited
  • Sogetel inc.
  • Tuckersmith Communications Co-operative Limited
  • Wightman Telecom Limited
  • WTC Communications