At this point in time I'm not aware of any jurisprudence that talks about the distinction. Of course, for other categories of rights holders, as I mentioned previously, the communication right is a technologically neutral right. It's been interpreted so as to apply on the Internet, but that doesn't deal with what the broadcaster emits in terms of a signal; it deals with the content that's actually being disseminated.
On September 25th, 2006. See this statement in context.