Letter to the Editor: CPCC responds

Dear Editor, The article published on September 8, 2004 (CPCC asks for new audit powers to deal with recalcitrant CD manufacturers) contains numerous misstatements and exaggerations. CPCC is not seeking new audit powers or strict new regulations. What CPCC is actually seeking is clarification of the current tariff wording regarding CPCC’s audit right. Mr. Knopf’s assertion that these clarifications are inappropriate and overarching is baffling. CPCC is requesting that the current wording in the tariff be amended to specifically state that the records manufacturers and importers are obligated to keep be original source documents which are sufficient to determine all sources of supply, volume of media acquired or manufactured and the disposition of such media. This wording reflects the intent of the existing audit provisions and simply eliminates ambiguity. Further, CPCC proposes that auditors be entitled to conduct all reasonable procedures and make all reasonable inquiries inside and outside (the company) required to confirm the completeness and accuracy of the information reported to the CPCC. Defining the scope of CPCC’s audit right will ensure that CPCC and manufacturers/importers have a clear understanding of the audit obligations. The assertion that the amendments are being sought because CPCC finds it increasingly difficult to enforce the tariff is incorrect. In the course of conducting audits, CPCC identified shortcomings in the current wording and has taken steps to rectify the problem. While the current wording may have limited the effectiveness of past audits in some cases, it has not prevented CPCC from strengthening its tariff enforcement activities. This is demonstrated by the fact that CPCC is currently in litigation with ten companies. CPCC’s ability to verify the accuracy and completeness of the information reported by manufacturers and importers is an important tool in ensuring compliance with the private copying legislation and equitable treatment of all companies subject to the levy. Regards, (signed) Anna Bucci Executive Director, Canadian Private Copying Collective

Letter to the Editor: CPCC responds

News | 09/17/2004 4:00 am EDT

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