Re: Liability of Institutional Repository Managers?

From: Charles W. Bailey, Jr. <cbailey[_at_]uh.edu>
Date: Fri, 03 Jun 2005 17:50:46 -0400


Thanks again for the assistance. It appears that having a distributed school/department screening system does not get IR managers off the copyright violation hook and that it is uncertain whether they face liability under foreign laws if copyrighted works submitted to the IR that are published by foreign publishers are included in the IR against the policies of those publishers.

Since they endanger their potential immunity under the DMCA "service provider" exemption if they or other university officials screen submissions, and they face potential prosecution by foreign publishers if they do not, it seems that IR managers are between the proverbial "rock and a hard place."

Consequently, unless I'm missing something, the only safe course of action would appear to be to screen every IR submission centrally using IR staff who are able to make well-informed judgements about the copyright status of each item and its relation (if any) to pertinent publisher policies and procedures governing e-prints and other documents, with them enforcing those policies and procedures so that no copyright violations occur.



From: JFN <jfnbl[_at_]earthlink.com>
Sender: "CNI CGP List Manager" <cgplmgr[_at_]cni.org> Subject: Re: [CNI-(C)] Re: Liability of Institutional Repository Managers? Date: Thu, 02 Jun 2005 15:45:30 -0400
To: CNI-COPYRIGHT[_at_]cni.org

At 10:45 PM -0400 5/31/05, Charles W. Bailey, Jr. wrote:

    So, it would appear that under "service provider" immunity,     IR manager's should (1) not use the IR for commercial     purposes, and (2) not screen IR submissions in any way.

That makes it easy but it doesn't necessarily make it helpful. There's a big gap between no commercial purpose and no screening, on the one hand, and a "financial benefit directly attributable to the infringing
activity" and "the right and ability to control such activity," on the other hand. You don't want to foreclose the opportunity to recover costs, or abandon the right to reject submissions, if you don't have to.

    If so, three questions remain:

(1) If departments (not the IR unit) screen submissions, are
    they liable? (It would appear so.)

(2) If IR managers deposit works for faculty, have they
    tainted their noninvolvement in the deposit process and lost     immunity? If not, should they screen works they deposit for     faculty or not?

This is why we don't charge for advice on CNI-C. You raise an issue that hadn't occurred to me. The "department" and "units" and "managers" and "faculty" may all just be parts of a single entity. Service provider immunity probably presumes an arms-length relationship between the content provider and the service provider. You can't immunize infringement by Content, Inc. just by running it through a wholly-owned subsidiary called Service Provider, Inc., much less by hiring a Service Manager to work in a different office down the hall from the Content Creator.

(3) What is the impact of foreign law, especially European
    law, on the situation, since the copyright holders may be     non-US publishers?

Good question and another one that didn't occur to me. Service provider immunity is a sort of artifact imported by statute from the historical legal regime for common carriers -- you couldn't sue Ma Bell if you got an obscene phone call because common carriers weren't responsible for the content they carried. Whether and to what extent foreign laws adopt a similar approach for internet service providers and website operators is a question that could cost a lot of money to get a very iffy answer, and might be one of those questions that are cheaper to answer by forging ahead and waiting to see what happens. Not that I'm recommending it. John Noble


Best Regards,
Charles

Charles W. Bailey, Jr., Assistant Dean for Digital Library Planning and Development, University of Houston, Library Administration, 114 University Libraries, Houston, TX 77204-2000. E-mail: cbailey[_at_]uh.edu. Voice: (713) 743-9804. Fax: (713) 743-9811. DigitalKoans: http://www.escholarlypub.com/digitalkoans/ Open Access Bibliography: http://www.arl.org/pubscat/pubs/openaccess/ Scholarly Electronic Publishing Bibliography: http://info.lib.uh.edu/sepb/sepb.html Scholarly Electronic Publishing Weblog: http://info.lib.uh.edu/sepb/sepw.htm Received on Sat Jun 04 2005 - 01:50:46 GMT

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