Copyright, Libraries and Advances in Technology

Libraries are a fundamental institution in our society. Synonymous with learning and knowledge, libraries allow users to pursue information by providing access to a range of literary and non-literary materials. This system of learning from and building upon the ideas and work of others is key to a library's function in society. 

Accordingly, copyright provisions have a significant impact on the function of libraries, effectively restricting the way in which the library materials can be used. In order to overcome these restrictions, 'fair dealing' exceptions have been established, allowing libraries to provide materials, particularly for the purposes of study and research, without infringing the copyright provisions.

The role of libraries is evolving. As new technology is developed, facilitating the communication of information and ideas, libraries have been among the first institutions to incorporate such technology into their day to day operations. However, the introduction of this technology has had a significant impact on the interaction between libraries and copyright provisions. In order to adopt these technologies facilitating the communication of ideas and materials for library users, libraries have been required to implement new regulations in order to adhere to appropriate standards of copyright protection. Our presentation will explore the complex and evolving relationship between libraries, copyright provisions, and the adoption of new technologies designed to facilitate communication throughout the 20th and 21st centuries. 

The Development of Copyright - University of New South Wales v Moorhouse & Angus & Robertson (Publishers) (1975) CLR 1

I Photocopiers - a Threat to Copyright

During the 20th century, the invention of the photocopier radically improved the ease with which material could be copied and distributed. Photocopiers soon became an essential service provided by libraries for the use of those copying their own work, or those works available to them from the library catalogue. In relation to educational institutions in particular, 'the use of those machines may be regarded by some as a convenient - indeed almost indispensable - facility for the use of students and teachers, but by others as gravely damaging to the value of literary copyright.'[1] Users of these machines would often copy large amounts, often the entirety of works, unwittingly infringing copyright regulations and depriving the copyright owners of revenue from sales and licensing. Accordingly, photocopiers became the first target of the ACC, a newly established body seeking to enforce owners rights under the Copyright Act 1968 (Cth).

The Australian Copyright Council (ACC) was created on an interim basis in 1968. A non-profit organisation, the ACC aimed to help creators and other copyright owners to exercise their rights effectively and promoting changes to the law to maximise the fairness of copyright.[2] 

The ACC were successful in their campaigns to introduce provisions into the Copyright Act regulating the use of photocopiers to reproduce work protected by copyright.[3] Provisions were introduced to limit the ability of an individual to photocopy a text without the permission of the author, providing that, unless the copying was being done for the purposes of fair dealing and on a limited scale, the user had to obtain the permission of the copyright owner to make a copy of the work. However, it soon became clear from the very low number of requests for permission being made to copyright owners that the regulations were not being complied with. The ACC were thus faced with an issue of enforcement. Copyright was being infringed by hundreds of users on different photocopying machines across the nation, making it impossible to enforce the regulations on an  individual level. As a consequence, the ACC went in search of a much larger defendant in order to test the limits of the regulations established under the Copyright Act.

The photocopier had become an essential service of libraries throughout Australia. As the fundamental purpose of libraries was also to provide access to literary works protected by copyright, the ACC identified these institutions as a primary source of copyright infringement. Thus, libraries were targeted as an ideal defendant for a test case seeking to establish the rights of copyright owners in relation to photocopiers.

II Establishing a Case

The ACC requested the advice of J.R. Kerrigan, QC, who advised that 'state and university libraries which offer coin-operated photocopying services are infringing the Copyright Act many times a day.'[4] As the ACC's negotiations with universities regarding the payment of royalties for the use photocopied material had proven unsuccessful, the ACC decided to bring the test case before the court. The University of New South Wales (UNSW) was chosen as the defendant for the action, as the Vice-Chancellor of the UNSW, Rupert Myers, was proving 'particularly difficult' in the negotiations for payment of copyright royalties.[5]  Having acquired its defendant, the ACC now went in search of a plaintiff. The ACC approached author Frank Moorhouse and his publisher, Angus & Robertson, who both agreed to take part in the action.  Fortunately for the ACC, Counsel George Masterman QC, an ASA member, agreed to take the case on for free.

III The Hearing at First Instance

With all the pieces in place, the ACC arranged for journalist Paul Brennan, a UNSW graduate, to photocopy a story from Frank Moorhouse's book, The Americans, Baby, at the UNSW library. Using this infringing activity as its cause for action, the ACC initiated the Moorhouse case in the Supreme Court of New South Wales in May 1974.

At the first instance, the Supreme Court held that, in this particular case, the university had not authorised the breach. However, beyond the infringing activity orchestrated by the ACC, the court found that the university had authorised other breaches of copyright by allowing books to be photocopied on unspecified occasions. This was a success for the ACC. However, the UNSW appealed to the High Court.

IV The High Court Appeal

In August 1975, three High Court Judges allowed the university's appeal, saying that no proof of other breaches had been presented before the court. However, Counsel for the ACC had entered a last minute cross-appeal on the grounds that the earlier court case should have found that the university had authorised Paul Brennan's breach of copyright. The High Court upheld the cross-appeal too, holding that the UNSW had authorised the infringement of copyright.

Although the case was brought before the court with the intention of creating a clear and precise set of rules for those providing access to photocopiers, the judges considered the question of whether the library had authorised the infringement of copyright to be 'a question of fact in each case what is the true inference to be drawn from the conduct of the person who is said to have authorized.'[6] Hence, the question of whether a person or organisation authorises the infringement of copyright depends on all the facts of the case, so that a decision on a particular set of circumstances may be of no assistance in other cases.[7]

In the Moorhouse case, the judges identified several factors that led to the conclusion that the UNSW had authorised the infringement of copyright.

Firstly, the court determined that the university was in a position to control both the use of the books and the use of the photocopy machines. Furthermore, the court found that the university should have been reasonably aware of the possibility that an individual may use the books and photocopy machines at their disposal to infringement copyright if adequate precautions were not taken.[8]

The UNSW argued that it had undertaken several measures intended to prevent the infringement of copyright by users of the photocopiers in its libraries, effectively discharging its obligation under the Copyright Act.

The university identified a library guide, provided to first year students in  1970-1973, which provided information on copyright regulations under the Act. The university argued that by making students aware of the copyright regulations, they had discharged their obligations. However, the court found that the guide, which simply referred library users to a copy of the Act, did not effectively convey to library users how to ensure that their actions did not amount to infringement.

The university further argued that the employment of attendants specifically for the supervision of the photocopy machines discharged their obligation. However, upon taking evidence as to the exact nature of the duties of the photocopier attendants, the court found that they were employed for the purpose of the general maintenance of the photocopiers, rather than supervision of their use.

The crucial element of the finding that the university libraries had authorised copyright infringement was the failure to place a notice detailing the requirements of the Copyright Act in the immediate vicinity of photocopiers. Although the UNSW had displayed notices, these were not adequate, as they set out the provisions of s49, regulating the use of photocopying by librarians, rather than for individuals. The court held that the notices were 'completely ineffective for the purpose for which they were apparently intended'.[9]

Therefore, the libraries of the University of New South Wales were found to have authorised the infringement of copyright, and that the unqualified supply of material provided in the libraries amounted to an invitation to copy.

V Post-Moorhouse Amendments

Section 39A of the Copyright Act, requiring a library to display the following notice close by the photocopying machine, effectively limits the liability of libraries arising from the Moorhouse case. By informing the users of photocopier machines of the regulations under the Copyright Act, the library does not authorise infringement, nor does it provide library users with an invitation to copy.

The reasoning of the Moorhouse case has also been codified in s36(1A) of the Copyright Act.[10] This section details the factors to be considered in deciding whether particular conduct amounts to authorisation:-

(a) the extent (if any) of the person's power to prevent the doing of the act concerned;

(b) the nature of the relationship existing between the person and the person who did the act concerned;

(c) whether the person took any reasonable steps to prevent or avoid the doing of the act, including whether the person complied with any relevant industry codes of practice.

These criteria have been reasonably clear for establishing the obligations of libraries in relation to the provision of photocopying services. The display of the appropriate notices in the immediate vicinity of photocopiers discharges a libraries' obligations, ensuring that they do not authorise copyright or provide an invitation to copy.

However, as technology advances further, beyond the sphere of hardcopy works produced by photocopiers to digital material produced by computers, the action required by libraries to ensure that they do not authorise the infringement of copyright has also evolved.

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[1]  University of New South Wales -v- Moorhouse & Angus & Robertson (Publishers) Pty Ltd (1975) 133 CLR 1 per Gibbs J, 12.
 

[2] Peter Meredith, 'Realising the Vision: A History of Copyright Agency Limited 1974-2004', (Copyright Agency Limited, Sydney 2004), 9.
 

[3] Copyright Act 1968 (Cth) s21(1).
 

[4]  Ibid.
 

[5] Ibid, 11.
 

[6] per Bankes L.J. in Performing Right Society Ltd. v. Ciryl Theatrical Syndicate Ltd. (1924) 1 KB 1, at p 9, University of New South Wales -v- Moorhouse & Angus & Robertson (Publishers) Pty Ltd (1975) 133 CLR 1, per Jacobs J, 21.
                       

[7]  University of New South Wales -v- Moorhouse & Angus & Robertson (Publishers) Pty Ltd (1975) 133 CLR 1 per Gibbs J, 12.

[8] Ibid, 14.
 

[9] Ibid, 17.
 

[10] 1968 (Cth).
 

Libraries and Digitisation

 I Digitisation and Libraries

Digitisation is the process of converting information from an analogue format into a digital format. “Digitisation 

is an example of a supply-chain activity – one which generates an output (a product) based on a managed input (raw materials) which is distributed and transacted with an end-user.”[1] Digital images are electronic snapshots taken of a scene or scanned from documents, such as pictures, books, printed texts, and artwork. The digital image is sampled and mapped by pixels, which are a grid of dots or picture elements. Every pixel has a tonal value represented in a binary code. The binary digits are then interpreted and read by the computer to produce an analogue version for display or printing.[2]

Text, images and audio can be digitised. A scanner is able to capture an image and convert it to an image file. Then to identify each alphabetic letter or numeric digit and convert each character into an ASCII code, it is necessary to use an optical character recognition (OCR) program which analyses a text image for light and dark areas. During the analogue-to-digital conversion process, a continuously variable signal is changed into a multi-level signal without altering the essential content.  OCR allows for a library user to search a database with keywords just like any online article.  The process of converting materials into searchable documents on a computer can be tedious.  In the past, the only options for digitisation were  expensive and time-consuming, such as having works double-typed and then married to erase inaccuracies. Now, OCR technology allows  works to be converted to their computerised equivalents while retaining the look of the text itself as well as allowing for recognition of the individual letters and words.  The ANU currently only has one work that has been successfully  digitised  to be accessible using OCR, though it is currently unavailable.[3]

A Issues Regarding Digitisation

The increasingly digital environment is changing the way in which libraries fulfil their aim to preserve and provide access to knowledge for the public. There are growing expectations for libraries in the 21^st Century to provide access to knowledge and works held in their collections in digital formats via online databases, websites, and online repositories.[4] Due to the digitisation of cultural heritage institutions’ collections, information previously only available to a select group of people becomes accessible to the broader public.  An original historical document may only be accessible to people who visit its physical location, but if the document content is digitised, it can be made available to people worldwide. There is a growing trend towards digitisation of historically and culturally significant data.

The nature of the digital environment on the one hand and the purposes of the copyright legislation on the other hand have led to some tensions. These tensions arise because of different attitudes towards digitisation between users and authors. Users consider digitisation as an advantage for the public to gain access to knowledge and works. However, authors consider digistisation to be a loss of control as to how works may be used, and thereby creating a disadvantage for the owner, who suffers economic loss from the unauthorised use of their works. 

B Digitisation and Australian Copyright Law

Digitisation of a work in digital format is a reproduction of a work, and will constitutes copyright infringement unless it falls under an exception.[5] Three requirements must be satisfied in order for a work to be protected by copyright: The work  must be original, and a form of expression, in a material form.

In March 2001, the Copyright Amendment (Digital Agenda) Act 2000 (‘Digital Agenda Act’) came into effect and amended the Copyright Act 1968. The Digital Agenda Act expanded copyright owners’ rights in several ways. For example, it confirmed that converting a work into, or from, a digital form, reproduces the work and infringes the Copyright Act. This means that copyright owners of analogue works have the rights to the first digitisation of the work.

In relation to literary works, once a  work is protected by copyright, the owner of that copyright has the exclusive right to:

o   Reproduce the work in a material form;

o   Publish the work;

o   Perform the work in public;

o   Communicate the work to the public or;

o   Make an adaption of the work.

Digitisation and communication of a copyrighted work or a substantial part of a copyrighted work is therefore a copyright infringement of the work. Thus, libraries cannot digitise copyrighted works unless they rely on a licence, assignment or a statutory exception to use the work.

Currently, Australian libraries are undergoing an extensive digitisation process. By 30 June 2011, a total of 174,250 collection items had been digitised at the Australian National Library. This number is growing as more works are added to the libraries online digital collection.

The barrier to digitisation for libraries lies in the costs of clearing rights and the negotiation of individual licences. Despite these costs, libraries are persevering with the digitisation of works in order to meet the new challenges and expectations of the role of libraries in the 21^st century.

C Disadvantages of Digitisation

1  Copyright Problems

The process of digitisation  creates substantial challenges for  libraries, including the potential for creation and dissemination of digital works by libraries users in a manner which infringes the copyright of the works. Not only does digitisation allow almost any text, sound or vision to be digitally reproduced, but the technology is commonplace. It puts in users’ hands the capacity to make and disseminate multiple and perfect reproductions of works.[6] ‘The existence of widespread, large-scale infringement may severely impact upon commercialisation activities and the potential market for a copyright owner’s work’.[7] If one legal reproduction is accessed or made under a statutory provision, it is relatively easy to make more unauthorised reproductions without permission from the copyright owner.

2 Cost and Time

The second negative implication is the cost of the project. The cost includes  paying the wages and salaries of the staff tasked with operating the equipment to carry out the digitisation, the equipment itself, the contracts entered into with outsourced companies, and the costs involved with the ongoing preservation of the original work. Furthermore, the process of digitisation using OCR is an extremely time consuming process, with the most advanced machines operating to scan pages at a rate of 2.5 pages per hour. [8]

D Advantages by Digitisation

1 Easy access for the public

One of the major goals for libraries is easy access to the library collection for the public. Thus, the libraries consider digitisation to be positive  because ‘digitisation offers avenues for better preservation and wider dissemination of works, in less costly ways than previously possible’.[9]  A broader access not only refers to the number of people who have access to the information, but also to the ability  of users to search collections rapidly from anywhere at any time. Viewers can find the information  they are searching  for quickly and independently from the libraries. The material found by the user can also be printed directly from the web. Internet access is extremely widespread in modern society, and therefore digitisation of works constitutes a significantly easier way to access knowledge which  has been put online. Furthermore, content that is accessible online   is easy and comfortable for the user to read, especially for larger works on computers, laptops, tablets and special programs for e-books.  There are many examples of this new type of digital project, including  the Making of America website and the Library of Congress’s American Memory page, where the user is able to listen to online recordings  of Thomas Edison.[10]

2 Benefit the Owner

Digitisation can  also benefit copyright owners by increasing the accessibility of their works. For example, out-of-print works are now accessible online where they may have been extremely rare and difficult to source before digitalisation.

Moreover, the improved  access may lead to a greater interest in the work, and with a  greater interest, the owner can generate more income  from libraries’ licences to the specific work. ‘Legally, cultural institutions must obtain the consent of copyright owners for many acts of digitisation, through negotiating licensing arrangements. Practically, this appears to place greater power in the hands of copyright owners to dictate the circumstances in which digitisation and communication take place’.[11]

3 Out-of-copyright

The copyright protection expires a certain number of years after the death of the owner depending on the type of the work. When the copyright expires,  third parties are free to use the work  as they will. For example in 2007 the National Library of Australia, in collaboration with state and territory libraries, embarked on its first mass digitisation project, the Australian Newspapers Digitisation Program. The program digitised out-of-copyright newspapers and was estimated to comprise 40 million news stories.[12]

4 Preservation

Some objects, such as manuscripts or ancient books and paintings, if handled frequently or improperly, can be easily damaged. The risk  of such damage can easily be reduced by making high-quality digital images of the work which are available electronically instead. Digital material doesn’t need to be reshelved or located by the staff of the institution, as everything is located in soft copy format on the web. Digital copies are not a replacement of the original copy because digital copies are not permanent.  In fact, it is necessary to periodically transfer them to new formats. Digitalisation can preserve works where the works have fragile peripheral parts, such as frames and binding.[13]

E Libraries exceptions

The Copyright Act 1968 does not contain a specific exception that cover digitisation at libraries or other mass digitisations for the purposes of providing increased public access to works.

However, there are a number of exceptions that allow libraries to digitise collection items for defined purposes, such as:

o    responding to user requests or requests by other libraries for copies of published works for the purposes of research and study;

o    certain reproductions, when made by or on behalf of researchers;

o    administrative purposes;

o    the preservation of manuscripts, artistic works, sound recordings; and

o    replacing a published item that is not commercially available.[14]

The issue in question then is how these rules are to be interpreted. For example, infringement of copyright is justified in the case of digitisation of books, pursuant to s 49 of the Copyright Act, which provides for ‘responding to user requests or requests by other libraries for copies of published works for the purposes of research and study’.[15] There is no doubt that library users gradually request and expect access to knowledge online. However, because the Copyright Act came into effect in 1968, the provisions have not contemplated the possibilities of library digitisation. 

One argument is that the digital environment is so different from the analogue one that copyright owners’ rights should be expanded, and statutory exceptions and limitations, which traditionally exist in copyright legislation, should be more limited in their application. ‘One reason this strengthening is seen as necessary is to remove a great obstacle to electronic dissemination of works: a heightened fear of infringement’.[16] The digital environment makes it easy to reproduce works, especially because the electronic products are well-known by the users. Thus, this argument suggests that copyright exceptions that have existed for analogue use should be restricted for the purposes of digital use.

On the contrary, it can also be argued that digital communications do not require a restriction of the statutory exceptions. A restricted interpretation of the copyright exceptions leads to increased powers of control for copyright owners that may be used to suffocate the access to knowledge or ‘lead to a “pay-per-use” economy in digital information’.[17]

Therefore, there are arguments for and against a restricted interpretation of the copyright exceptions. However, because they have not been subject to any cases,  the exact legal standpoint is not yet clear .

F Is a reform of the Australian Copyright Act Necessary?

A stated aim of the Copyright Amendment (Digital Agenda) Act 2000 was to ‘ensure that cultural and educational institutions can access, and promote access to, copyright material in the online environment on reasonable terms.’[18] In light of this aim, it can be considered that reform of Australian copyright law is necessary due to the fact that the current Copyright Act does not contain any exceptions for the use of digital content by libraries.

The balance between copyright owners’ rights and the public interest in access to copyright material is a key issue in digitisation, and as outlined  above, there are many views on digitisation in the context of copyrights.

The Australian Law Reform Commission does not suggest a particular method for  reform of the Copyright Act, but welcomes comments on whether specific exceptions or broader exceptions are the most effective in a digital environment.

The importance of digitisation will certainly increase in the coming decades. Institutions should concentrate more on planning  the goals of a project  than the technological aspects. Accordingly, goals must be determined at first, so that institutions should focus their attention on which technologies are the most  useful in achieving  that goal. Thus, setting the goals and objectives of the project is fundamental. The goal should be well defined and specific. The mains issues to be determined are the types of users that will be using the resources, why the users should look for this particular material, how the website will be used and the quantity of people who will use it, and last but not least, how the digitised material will benefit the users and the institution.

II Approaches to Digitisation at the ANU Libraries

Much of the information from this section comes from interviews with ANU library staff in Menzies and Chifley Libraries and Ms Roxanne Missingham, ANU's Chief Scholarly Information Officer, to whom the ANU Digitisation Committee will report.[19]

A Statutory Background

The Copyright Act 1968 (Cth), in s 200AB, says that the usage (in the case of a library, loaning and dissemination) of a work does not breach copyright where each of the conditions of subs (1) are met, those being:

           (a) the circumstances of the use ... amount to a special case;

           (b) the use is covered by subsection (2), (3), or (4);
           (c) the use does not conflict with a normal exploitation of the work or 
           other subject-matter; 
           (d) the use does not unreasonably prejudice the legitimate interests of the 
           owner of the copyright.

The relevant subsection as described under (b) is (3), which refers to educational institutions, under which the ANU libraries fit.

There is a “fair dealing” provision of the Copyright Act in s 40, which relevantly reads:

(1A) A fair dealing with a literary work … does not constitute an infringement of the copyright in the work if it is for the purpose of, or associated with, an approved course of  study or research by an enrolled external student of an educational institution.

The ANU, in digitising its resources, intends to rely extensively on s 200AB.  A newer section in the Copyright Act, it has been subjected to far less judicial scrutiny, so its usefulness to libraries is hitherto uncertain.

B Representation

ANU is a member of Universities Australia, the peak industry body representing 37 universities in Australia who pay an annual fee of nearly $24 million to CAL for the use of copyright materials in campus libraries.  Universities Australia has been given the option of making a submission to the Australian Law Reform Commission about improving copyright laws so as to promote efficient digitisation while retaining the rights of authors.

C How ANU Digitises

The few materials at ANU that have been digitised have been done by contracting out or with the resources the ANU itself owns, although these are limited, and equipment with OCR capabilities is even more so.  The university is host to the National Centre of Biography and owns one Guardian scanner, which is a flat imaging machine.  The process of digitisation is extremely slow and one machine is not an efficient or effective way to digitise the vast resources of the university.[20] ANU often contracts out for digitisation and this is its intention for the future.  For example, one company that digitises documents and books is Document Imaging Services in Braddon.  Menzies has used this company in the past, and they have cradle imaging capabilities, which allow for books to remain only partially open when being scanned as opposed to entirely flat, which can warp or ruin the spines of the originals.

D Relevant Categories of Sources for Ongoing Digitisation

ANU has been hesitant to be a forerunner digitising its library resources because of the lack of clarity in the Copyright Act as it currently stands. Especially with the operation of s 200AB being so uncertain, the university is unwilling to exert too many resources on mass digitisation. But despite these difficulties and uncertainties and copyright law restricting which materials can be distributed by libraries digitally, there are realistically three categories of resources that can be digitised without complex legal problems:

1 Materials Whose Copyright Holders Are Easily Contactable

These are the rarest category, but will often require some form of payment to the copyright owner.

2 Old Materials with Expired Copyright

Due to lapse in time (75 years from the death of the author or creator of the work), copyright ceases and the ANU can reproduce the work digitally.

3 ANU Theses

Starting from January this year, students writing theses at ANU will be required to submit their final work for publication by the university to be made available. There is provision for delay of publication where the writer intends to publish material outside the university on the subject.

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[1] Collections Trust, Comité des Sages of the European Commission, The Cost of Digitising Europe's Cultural Heritage (2010), 11.
 

[2] Moving Theory into Practice, Cornell University Library, <http://www.library.cornell.edu/preservation/tutorial/intro/intro-01.html>.
 

[3] Some Notes on Java and its Administration by the Dutch, ANU Library <http://anulib.anu.edu.au/subjects/ap/digilib/indo/java/>.
 

[4] Australian Law Reform Commission, Copyright and the Digital Economy (IP42) (2012) <http://www.alrc.gov.au/publications/issues-paper/libraries-archives-and-digitisation>.
 

[5] Copyright Act 1968 (Cth) ss49-51.

[6] E Husdon and A Kenyon, ‘Digital Access: The Impact of Copyright on Digitisation Practices in Australia Museums, Galleries, Libraries and Archives’ (2007) 30(1) UNSW Law Journal 12 (, ‘Digital Access: The Impact of Copyright on Digitisation Practices in Australia Museums, Galleries, Libraries and Archives’).
 

[7]Ibid.
 

[8] Document Imaging Services, ScanRobot 2.0 MDS (20 September 2012) Document Imaging Services <http://www.docimaging.com.au/equipment/?product=ScanRobot2.0MDS>.

 

[9]   Australian Law Reform Commission, Copyright and the Digital Economy (IP42) (2012) <http://www.alrc.gov.au/publications/issues-paper/libraries-archives-and-digitisation>.

[10]Trevor Jones, An Introduction to Digital Protjects for Libraries, Museums and Archives (May 2001) University of Illinois <http://images.library.uiuc.edu/resources/introduction.htm>.
 

[11]  E Husdon and A Kenyon , above n7. 
 

[12] National Library of Australia, Australian Newspapers Digitisation Program <www.nla.gov.au/ndp/>.
 

[13] Trevor Jones, An Introduction to Digital Protjects for Libraries, Museums and Archives (May 2001) University of Illinois <http://images.library.uiuc.edu/resources/introduction.htm>.
 

[14] Copyright Act 1968 (Cth), ss 49-51(A).

[15]  Ibid.
 

[16] E Husdon and A Kenyon , above n 7. 

[17] E Husdon and A Kenyon , above n 7.
 

[18] ‘Digital Access: The Impact of Copyright on Digitisation Practices in Australia Museums, Galleries, Libraries and Archives’.
 

[19] Special committee comprised of three library staff from different academic areas tasked with assessing the viability of digitising ANU's library collection.

[20] Document Imaging Services, ScanRobot 2.0 MDS (20 September 2012) Document Imaging Services <http://www.docimaging.com.au/equipment/?product=ScanRobot2.0MDS>.