We write with respect to the Court’s direction dated April 24, 2020 (“the Direction”), addressing in part CIPPIC’s Motion for Leave to Intervene in the above- referenced proceeding. [...] Our submissions particularly demonstrate a unique focal point to analyzing the central issues before the Court: the precisely articulated enforcement role(s) different types of Internet intermediaries play at law, which explicitly informed Parliament’s approach in adopting the Copyright Act reforms at issue in this Appeal.1 This lens and the legal principles accompanying it inform all of CIPPIC’s. [...] In addition, CIPPIC undertakes to curtail elements of its submissions addressed in those of the British Columbia Civil Liberties Association or the Canadian Internet Registration Authority (the “Other Proposed Interveners”), should one or both of them obtain leave to intervene.4 Please do not hesitate to contact us should you have any questions or concerns. [...] Yours very truly, Caza Saikaley srl/LLP Samuelson-Glushko Canadian Internet Policy& Public Interest Clinic James Plotkin Tamir Israel Counsel for the Proposed Intervener, Counsel for the Proposed Intervener, CIPPIC CIPPIC CC Colin Baxter (counsel for the appellant, Teksavvy Solutions Inc) François Guay (counsel for the respondents, Bell Media Inc, Groupe TVA Inc, Rogers Media Inc) Timothy M. [...] Lowman (counsel for the respondent, Distributel Communications Limited) Vincent de Grandpré (counsel for the respondent, Telus Communications, Inc.) Emily Lapper and Gib van Ert (counsel for the proposed intervener, BCCLA) Bram Abramson and Jeremy de Beer (co-counsel for the proposed intervener, CIRA) Gavin MacKenzie and Brooke MacKenzie (counsel for the potential intervener, FIAPF) Eric Mayzel an.
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