CP1500 Lecture Notes - Software Piracy


Table of Contents


Number One Crime - Software Piracy

Software piracy is the illegal copying of software. Software piracy is the number one computer crime both in terms of dollars involved and number of people involved. So why do people pirate software?

Piracy Evils

Most piracy occurs in S.E. Asia and the Middle East, where perfect copies of software, including manuals and vendor holograms, are produced and sold openly in markets at reduced prices. Software vendors are very interested in preventing piracy and/or punishing those who engage in it. Here is the software vendor argument against piracy. It is difficult to believe some of the industry claims because many companies (such as MicroSoft) are hugely profitable. But how are small companies impacted by piracy?

Piracy Protection

There are three primary legal means to protecting software.

Copyright Law

Copyright law applies to the originality of the expression of an idea rather than to the novelty of the idea itself.

Does Copyright Apply to Software?

Three special issues in copyrighting software. Copyright was developed for literary, artistic, and musical works. Law has to be extended to cover software. How far to extend copyright law is argued in court cases.

History of Copyright Law and Computers

Look and Feel Suits

Courts have yet to fully define what is meant by ``look and feel.''

In the late 1980s, Lotus 1-2-3 sued two ``look-alike'' products and won. Then Visicalc sued Lotus since head of Visicalc went to Lotus and Lotus looks a lot like Visicalc, but court found that Lotus was ``different'' enough.

Also in the late 1980s and early 1990s, Apple sued Microsoft on the basis of apparent similarities between MacIntosh interfaces and Windows. Initially Apple won, but recently that decision was overturned. Xerox then sued Apple since Xerox developed a MacIntosh-like interface prior to Apple's development. Moreover, Steven Jobs, a programmer at Xerox, left Xerox to start Apple and hired ex-Xerox programmers to work on the MacIntosh. But Xerox also lost.

Patent Law

History of Patent Law and Computers

Trade Secrets

A Table of Summarising Legal Protections

Copyright Patent Trade Secrets
cost of obtaining nil moderate moderate
cost of maintaining nil nil moderate
availability wide narrow narrow
"process" protectable? no yes yes
suited to mass distribution yes yes no

Other Schemes

Companies have come up with software solutions to protect against illegal copying. These schemes include the following.

Busting the Pirates

Legal Protection of Computer Software

Protection of the rights to intellectual property has been traditionally achieved through the patent and copyright laws.

Computer programs or software is a relatively new type of intellectual property.

Legal protection of computer software is desirable for the following reasons:

  1. Investment and Time Required: The investment in computer software is large perhaps of the order of US $20-30 billion annually. Not only large-scale investment but also protection of the small software enterprise or individual creator of software.

    The existence of strong legal protection would encourage the dissemination of their creations and enable such creators to avoid duplication of work.

  2. Likely Future Developments
  3. Protection as an Incentive to Disclosure
  4. Protection as a Basis for Trade
  5. The lack of legal protection may be particularly harmful in the context of trade. Both the seller and the buyer of computer software are interested in legal protection because it increases the legal security of their relationship.

  6. Vulnerability of Computer Software

In summary, computer software accounts for greater part of the high investment in computer technology and its creation requires a high degree of intellectual effort.

To encourage investment and trade in software and promote wider accessibility, software deserves to tbe provided with effective legal protection.

Review Of Available Options

Copyright protection and patent protection. In practice, most software producers believe copyright protection to be ineffective and in most countries patent protection is not available to software.

Therefore the producers of software have relied on the law of confidence, trade secrets, trade marks, supplying the software in binary form or using cryptographic techniques.

Copyright Protection

Usually associated with literary, dramatic, musical, and artistic works.

The copyright law is relevant to protection of software as well as documentation since these may be considered literary works when dealing with copyright law.

The copyright protection is not available to the ideas in the work but the protection focuses on protecting the form in which ideas are expressed.

This seems particularly appropriate for software and its documentation because in most cases the intellectual creativity in computer software resides in the skill and effort used to produce a particular form of software.

The four major rights of the copyright owner are the reproduction right, the publication right, the translation right, and the right to prevent dealings in illegal copies.

The right to reproduce, is a right to copy a work in any material form (it is not clear whether material form requires a visible representation of work) and reproducing a substantial part of the work is also an infringement.

The right regarding translation and adaptation would seem to include translation of the source code of a program to object code and from one computer language to another.

Copyright protection is available as soon as the work is completed and is available internationally.

There are two worldwide conventions relating to copyright proper, namely the Berne Convention of 1886 last revised in Paris in 1971, and the Universal Copyright Convention (UCC) of 1952, also revised in Paris in the same year.

The UCC was a bridge between the U.S.A., which was unwilling to join the Berne Convention, and the countries of Western Europe and the Western Alliance, who were members.

Both certain minimum standards of protection must be given like a minimum term of protection of life of the author plus 25 years.

In spite of the international protection provided by copyright and the fact that it is very cheap and simple to obtain, there are several areas of uncertainty. For example :

  1. Although visible form of software may be copyrightable, is a program on magnetic tape copyrightable?

  2. When a computer program is used in a machine, is it 'use' of the software (which is permitted) or its reproduction (which is not permitted)?

  3. The copyright law does not confer on the owner an exclusive monopoly. Therefore, another author creating independently a similar or identical work does not infringe the copyright of the first author. Since copyright requires publication of the work, another person may copy the work substantially and claim to have created it independently. In literary works, independent creation of same work is considered unlikely. Is it more likely in computer programs?

  4. Is translation of a program carried out by a computer forbidden?

Patent Protection

Patent protection is usually available to new and inventive technical solutions.

A patent gives the patentee the exclusive right for 16 years (in Australia) to make, use, exercise, and sell the invention.

The Australian patent law allows patents to "the sole working or making of any manner of new manufactures" to the true and first inventor.

There is no definition of "invention" or "manner of new manufacture".

Recent legal opinion in Australia and overseas seems to be that patents are not appropriate for computer programs.

This is because patents are expensive and time-consuming to acquire and, although not tested in the courts, the opinion of the Australian Patents Office has been that "Computer programs, consisting of sequences of instructions on how a problem may be solved are not proper subject for letters patent".

In U.K., the Banks Committee (Report on the British Patent System, 1970) recommended that computer programs be excluded from patentability.

The European Patent Convention (1973) expressly excluded computer programs from patentability.

Trade Secrets

Trade secret protection is available to any information, device, formulae etc. to protect a business from unlawful or unethical acquisition of secrets by a competitor. Trade secret protection is a tort (civil) remedy. The law of trade secrets depends on non-disclosure or at least very limited disclosure of information. There are a number of laws which directly penalise or provide civil law remedies against the misappropriation of a trade secret or of information obtained in breach of confidence. Secret information can also be indirectly protected by certain provisions in criminal law, by general provisions in civil codes or by certain actions in the law of tort.

Trade secret laws do not require the subject matter to be novel or even original. Also the software need not (and should not) be made public as in copyright or patent law. The subject matter need not be expressed in any particular form. To protect any information under the trade secrets law, the owner of the trade secret must be able to prove the existence of the trade secret, the value of the trade secret to business and the owner's right to use the trade secret. The trade secret remedy will then be available to a person to prevent the wrongful use or disclosure of trade secrets where the other person is under an obligation of confidence not to disclose the information. If a person obtains the software without the owner's consent, it must be proved that the defendment obtained the trade secret unlawfully or unethically.

Other Forms of Protection

The laws of certain countries provide a number of means of preventing the unauthorised disclosure or use of secret information. There are a number of laws which directly penalise or provide civil law remedies against the misappropriation of a trade secret or of information obtained in breach of confidence. A common means of protecting information concerning computer software, which is provided by all laws, is by contract. Even in the absence of an express term in a contract, persons in a fiduciary relationship with a computer enterprise, such as its employees, can be prevented from disclosing secret information. Secret information can also be indirectly protected by certain provisions in criminal law, by general provisions in civil codes or by certain actions in the law of torts. Even in the absence of secrecy, the misappropriation of computer programs may, in certain circumstances, be actionable in the context of unfair competition law. However, even in countries where trade secrets can be protected directly, there is uncertainty or differences as to the scope of protection and as to the conditions (for example, whether disclosure to a licensee or to a restricted number of other third parties would prejudice the secrecy of the know-how protected). The disadvantage of protection under contract law is that in most cases it will be difficult to prevent persons outside the contractual relationship from disclosing or using a program. Moreover, one of the advantages of the establishment of clear and adequate legal protection for computer software is to encourage greater disclosure of information on computer software which would otherwise be vulnerable to misappropriation. The aim of such protection is therefore precisely to avoid any necessity to rely on secrecy and on laws and legal measures safeguarding secrecy. Reddien (1979) talks about contracts and how a contract should be formed.

We have discussed three different mechanisms of software protection. A comparison of three techniques using 13 different criteria is presented in the CONTU Report. We reproduce it below. Some other mechanisms like trade marks, contracts, licence have not been discussed here.


General Considerations
Copyright Patent
Trade Secrecy
------------------------------------------

1. National uniformity yes yes no

2. Protection effective creation of work successful entrance into prosecution of contractual

application relationship

3. Cost of obtaining nil moderate moderate protection

4. Term of protection life plus 50 17 years possibility of years or 75 years both perpetual protection and termination at any time

5. Cost of maintaining nil nil significant protection

6. Cost of enforcing rights moderatemoderatehigher against violators

7. Availability of (a) statutory damages yes no no (b) attorney's fees from yes yes no infringers

8. Protection lost by gross neglect unsuccessful disclosure litigation --------------------------------------

Software Considerations, Copyright Patent Trade Secrecy Including Effects of

Subcommittee Proposals

9. Consistency with other yes no no copyright areas

10.Availability of yes unclear yes protective mechanism for some programs

11.Universal availability yes no no of protective mechanism for all programs

12."Process" protectable no yes yes

13.Suited to mass yes yes no distribution

PRESENT SITUATION

At present software producers are using one or more of th e protections discussed in the last section. In a survey quoted by Anderson and Niblett (1976), ADAPSO in USA found that its members used the following techniques :-

Most software houses copyright listings and related documentation to obtain as much collective protection as possible. Anderson and Niblett (1976) present results of a survey undertaken in U.K. in 1975 about software protection. The survey found that 85% of respondents found contract with the customer effective protection, and trade secrets was also considered effective by a majority of respondents. Patents and copyright were considered not to be effective. Trade marks is also being used by a substantial proportion of respondents. Other techniques being used are supplying software in binary form and using cryptographic techniques.

SOLUTIONS

Several expert committee have now looked at the problem of legal protection for software. The important one have been :

The Whitford Report

The Whitford Committee found that almost all submissions to it called for a clear and effective protection for software either under the general law of copyright or under some special software legislation. It is suggested that legal protection will encourage speculative development of programs with a view to profit and encourage those who develop programs for their own use to make them available to others.

The Whitford Committee recommended that computer programs and software which have involved a sufficient degree of skill and/or labour be considered as works in the normal copyright sense. The Committee took the view that ``copyright should subsist in any original work which is fixed in such a way that the recorded information can be reproduced...'' and it felt the existing categories of literary and artistic works are sufficiently wide to cover computer programs. In the Committee's opinion it is immaterial that a program may not be visible to or readable by the human eye or be directly understandable by the human brain.

According to the Committee, copyright protection provides right to prevent reproduction and sale. It also restricts making adaptations which should include translation from one programming language to another and from source code to object code. The Committee expressed doubt about the protection available when program is used in a computer. In practice, it seems that use of a computer program in a computer necessarily involves reproducing some or all of the program in a store of the computer, but there is doubt as to whether such transfer necessarily constitutes reproduction of the program in the legal sense. The Committee recommends that storage of program in a computer should be a restricted act and that new legislation should explicitly say so.

Copyright protection does not restrict "use", for example, following a recipe set out in a cookery book. In case of computer programs, the whole point of the creation of the works is to exploit them by 'use' and it is to 'use' that the authors can expect to look to secure a return for their work. A majority of the Committee recommended that 'use' of computer programs should be an infringement.

WIPO MODEL PROVISIONS

The Model Provisions are intended to provide protection to computer software "which is original in the sense that it is the result of its creator's own intellectual effort". The provisions give the "proprietor" (creator of software or his employer) the rights to prevent the following : The first of these issues was studied by the Software Subcommittee. The subcommittee suggests that relatively small changes in the new copyright act would be required to provide a socially desirable and effective form of protection for computer programs. An alternative proposal by a member of the Subcommittee argues that computer programs should not be secured by copyright. Instead a special legislation for protection of software is proposed.

The Subcommittee concludes that software copyright should do the following :

CONTU received written and oral submissions from several witnesses. The majority of witnesses favoured copyright protection for software.

The CONTU recommendations are similar to those of WIPO and the Whitford Committee. The recommendations include the following :-

The 1976 Copyright Law (P.L. 94-553) provides statutory copyright protection to works prior to their publication as well as after their publication. Because of this concern has been expressed about a conflict between protection provided between trade secrets and copyright. CONTU found the trade secret protection of software having several disadvantages. These include hostility to the free exchange of ideas, ease of loss of protection, substantial expenditure in each transaction and non-uniformity in protection provided by various states of the USA.

It was reported at the end of 1980 that the Computer Software Copyright Act of 1980, H.R. 6934, based on the CONTU report was approved by the House Committee of Judiciary (See, CACM, September, 1980, p. 541).


Copyright © 1998 Curtis Dyreson. All rights reserved.