OSIA is thankful for the level of thought which appears to have been put into this draft. OSIA is also grateful that the Draft evidences an intention to balance the interests of domestic copyright holders and new media publishers (such as OSIA and its members) against those of foreign old media publishers.
By failing to permit interoperability between software and user data the Draft fails to support a free market for software. Section 47D in particular is out of date and needs to be updated. Both the Draft and section 47D should be changed to permit the interoperability between a program a user's data.
For further information see attached.