Every other collective licensing regime and even reproduction rights regimes in the act have clear rules that set out that an orphan, when they come forward later, have the right to claim moneys. It also sets out the ability for the Copyright Board to set clear regulations and clear limitation periods for claims and rules as to how claims come forward. In the absence of that, we're left relying on different provincial legislation, different legal opinions as to what our obligations may be to different rights-holders, and that's problematic because it's not clear; it's not transparent. What we're asking for is the clarity so that we know exactly whom we should be paying and how to go about doing it.
On February 28th, 2012. See this statement in context.