The Federation welcomed the opportunity to comment on the major points in this paper which covered the illicit peer to peer debate, the establishment of a Rights Agency and the proposal for legislative obligations and a Code for ISPs.

Although the software industry is possibly not challenged as much by illicit p2p file sharing as perhaps the music industry, it still suffers considerable loss due to this activity. The Federation feels that software should be treated as a special case as it is geared towards providing a service to the user and will become more so with the advent of software as a service etc.

The proposal to form a Rights Agency is not supported by The Federation, who believes that it will become ineffective, expensive and bureaucratic and will not assist rights owners in their fight against illicit file sharers.

With regard to the proposed legislative obligations and a Code for ISPs, The Federation broadly welcomed the initiative if it felt that it would reduce illicit peer to peer traffic.