Let me speak to one country that has not gone with the UPOV 91 model, and that is Norway. Norway stuck to UPOV 78, which is where we're trying to move from right now. The United States is a model for UPOV 91. France is a model for UPOV 91, but what France has done is completely eliminate the farmers' privilege. In the United States, what they have done is measure the ability of a farmer to be exempt from the farmer's right on the basis of the percentage of his income that is derived from the use of proprietary seeds. In itself, that is consistent with the UPOV that has allowed national governments to determine the extent of privileges they will grant to smallholder farmers.
There are several extremes to date: France is one. The United States appears to be the middle ground. Norway stuck to UPOV 78. I believe it is possible to recognize that the international treaty for the protection of plant genetics for food and agriculture, in article 9, helps us to really speak to farmers' rights in a meaningful way, that to also recognize that before plant breeding we had traditional landraces, which is a national patrimony, that may not yet have been affected by agricultural biotechnology. And those can constitute buffers for some crisis situations. We want to support these kinds of farmers, and also recognize that they also do informal research and development. These are the kinds of people who appear not to have been pre-empted by section 5.