For over 10 years we have voluntarily, and for free, been receiving and processing what we can with the systems we have. Some have automated more; some have not. Originally they were all being processed. But there was also some kind of dialogue with the ISP and the content owner.
We used to seek permission from the content owner so we could let our user know it was this content owner who was making the claim. Before we disclosed their name and their information, we wanted to make sure the content owner was satisfied that, yes, we could pass on the information.
It's something that started with a dozen a month and ballooned. In between we've had three bills. We're on our third copyright bill where we weren't sure exactly what the rules would be.
There are new obligations in C-32 that we continue to support but that we don't do today, and it's never been asked of us: for example, closing the loop with the content owner to say that, yes, we have passed it on; retaining the data about the customer--that's not something we do today, and it's not something we've ever negotiated with the content owner.
With the evolution, with the expectation of a bill, with the expectation to have the industry...we haven't been able to sit down with the content industry and say this is how the notices should be sent to us.