EIFL submitted comments to WIPO on a draft Scoping Study on Public Lending Right (PLR) (SCCR/45/7). The comments were submitted together with IFLA (International Federation of Library Associations & Institutions), LCA (Library Copyright Alliance, USA) and the Canadian Federation of Library Associations (CFLA-FCAB).

Overall, the comments highlight a lack of objectivity in the study and an assumption (erroneous in our view) that PLR is an appropriate means of incentivizing creativity in developing countries. Since significant further research would be needed to rectify these gaps, including with respect to issues outside the normal scope of WIPO's work, WIPO should not spend any more time or resources on this topic. 

The comments highlight the following issues: Access rights and human rights; PLR and the WIPO Treaties - Exhaustion and National Treatment; Marrakesh Treaty for persons with print disabilities; National policy objectives; National capacity requirements; Administrative costs; Developing countries; Europe - the source jurisdiction; PLR and e-books; Bias towards PLR; Misrepresentation of IFLA’s position.