Sure. I'm happy to do that.
It's important to stress at the outset that a lot of these different laws—and there aren't that many of them—where they do exist, such as in Germany, obviously reflect the cultural context and the historical context of certain countries. We always should be mindful of that and not necessarily say, “This is the model that exists; therefore, we should just adopt it holus-bolus in other countries, such as in Canada.”
That said, as I mentioned to Madam Raitt earlier, in Germany the challenge for us has been that because there are these very strict definitions or requirements on what the platform needs to do, you'll forgive me if I don't have the specific time frame, but within a very short period of time, let's say a day of reporting, content has to be removed. That obviously doesn't allow a lot of time for people to be certain that this type of content is in fact illegal or otherwise prohibited, and it doesn't allow a lot of time to prevent false positives.
In the last year or so that this law has been in place, if you look at some scholars who have looked at this a bit, what has happened is that platforms are over-rotating. I think there is generally this concern that if something is flagged and we don't take action on it, it's going to be a liability. There has been this general sense that perhaps platforms should be more aggressive in removing that content.
I don't know if that's a desired public policy outcome. In Canada, typically, we've thought about these things as trying to create as much space as possible for freedom of expression, not trying to censor people, but then also clearly identifying certain speech that should be prohibited. To get at that, we've always thought that having a measurement of prevalence, how much of that is out there, and holding companies responsible for reducing that amount and ensuring their processes are in place is a better way of thinking about it than focusing on specific pieces of content and you have x amount of time to get it down, because then you actually don't get at the fundamental challenges of what free speech is about.