In the limited time I have, in addition to those two points that Wally raised about disproportionate penalties and perhaps the wrong target audience, I would say that part of the problem with CASL enforcement is that we don't know where the lines are being drawn when enforcement decisions are made and put out. We only get vague summaries, and we don't really know what sorts of decisions are being made and how this is being interpreted.
The other point I would make is that I think there's a structural flaw within the law, in that all of the powers—the enforcement investigation powers—are given to staff members of the CRTC. The GIC appointees of the commission don't have a role and can't provide any guidance or input unless and until a notice of violation is actually issued and a party decides to effectively appeal that to the commission.