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Industry committee I can't speak for others, but IAB Canada is going to submit a more detailed brief. With respect, three pages is not sufficient for us to provide the range of types of use cases and other suggestions. We will present use cases so the committee can see how there is unnecessarily ex
October 17th, 2017Committee meeting
Adam Kardash
Industry committee I can speak on behalf of multiple companies, and I would add that certainly spam is hugely problematic for businesses too. They bear the cost. What we are trying to accomplish here is to reduce the cost of compliance, with the aim of the legislative scheme being that it should be
October 17th, 2017Committee meeting
Adam Kardash
Industry committee I'll start with a basic proposition. What we are hearing from clients every day is that, anytime you have uncertainty, you have risk, and that poses a problem. It doesn't completely stop innovation—that would be an overstatement—but it introduces a level of risk in which, in our
October 17th, 2017Committee meeting
Adam Kardash
Industry committee You could make changes consistent with Mr. Fekete's comments, and there's a ton of common ground with Dr. Geist. It might not appear that way, but there really is. You could make a series of tweaks to eliminate some unnecessary wording, to clarify the ambiguity—
October 17th, 2017Committee meeting
Adam Kardash
Industry committee For clarity, there isn't one enforcement body, but rather three, so it's quite complex. There's the Competition Bureau, depending on the provisions; the CRTC; and the Office of the Privacy Commissioner of Canada. In fact, depending on the nature of a particular activity, you coul
October 17th, 2017Committee meeting
Adam Kardash
Industry committee Well, it can be cumbersome. The CRTC clearly has the necessary tools to appropriately enforce against bad actors. That, again, is not our issue. Our issue is enforcement against the good actors, that and their not being subject to disproportionate penalties for technical, immater
October 17th, 2017Committee meeting
Adam Kardash
Industry committee I completely agree, as I said in my opening remarks.
October 17th, 2017Committee meeting
Adam Kardash
Industry committee Now, depending on the message—and this illustrates the complexity—either subsection 6(6) might apply or one of several exemptions could apply. It depends on the very specific context.
October 17th, 2017Committee meeting
Adam Kardash
Industry committee It's a display, yes; it's not sent. It's completely outside the ambit of the legislation.
October 17th, 2017Committee meeting
Adam Kardash
Industry committee There were comments unfortunately made by the CRTC and in the RIAS statement by what was then Industry Canada about the potential application to IP addresses, which is not, in our view, there, and you cannot have this legislative scheme apply.
October 17th, 2017Committee meeting
Adam Kardash
Industry committee We need scope of clarity.
October 17th, 2017Committee meeting
Adam Kardash
Industry committee It was a similar point made—
October 17th, 2017Committee meeting
Adam Kardash
Industry committee That would be devastatingly bad, yes.
October 17th, 2017Committee meeting
Adam Kardash
Industry committee Well, it wasn't unclear until statements were made by the CRTC and in the RIAS about the potential concept of electronic addresses applying to IP addresses. That's totally outside the scope of this.
October 17th, 2017Committee meeting
Adam Kardash
October 17th, 2017Committee meeting
Adam Kardash