Module 2: The International Framework

By Petroula Vantsiouri and William Fisher

Learning objective

This module discusses international copyright law. It explains how international copyright law works, how it affects developing countries, and how developing countries can affect it.

Case study

“I want to participate to an international exchange program, what should I know?”

Nadia works as a librarian in Mexico. She is very familiar with Mexican copyright law but wants to travel and work abroad. She plans to apply for an exchange program so that she can spend six months working in another country. Her options include Ethiopia, Russia, India, and Belgium.

The exchange program requires that Nadia be familiar with the copyright law in the country where she will work. She must understand the following issues:

• general standards of protection for copyrighted works,
• protection of performers and producers of sound recordings,
• copyright protection of computer programs and databases,
• moral rights protections for authors of creative works, and
• exceptions or limitations to copyright law.

Another librarian suggests that Nadia check whether her possible host countries have signed the same copyright treaties as Mexico. She tells Nadia that these treaties may set certain standards for the copyright law of every country that signed it. However, she cautions Nadia that the laws may not be exactly the same, and that even if a country has signed the treaties, the treaties may not have been fully implemented.

The Rationale for the International System

As we saw in Module 1: Copyright and the Public Domain, each country in the world has its own set of copyright laws. However, the flexibility that most countries enjoy in adjusting and enforcing their own laws is limited by a set of international treaties.

Why do we need any international management of this field? There are two traditional answers to this question.

First, without some international standardization, nations might enact legislation that protects their own citizens while leaving foreigners vulnerable. Such discrimination was common prior to international regulation.

Second, it is easier for everyone to know the protections and freedoms of copyright law if there are some similarities across countries. It is especially beneficial for authors and artists to know what protections are available to them in a globalized world.

Finally, some copyright holders - especially media production firms - believe that developing nations would not enact strong domestic copyright law unless forced to do so by treaty. Representatives of developing nations strongly dispute this argument.

International Instruments

The simplest way to achieve these goals would be single treaty signed by all countries. Unfortunately, the current situation is more complex. Instead of one treaty, we now have six major multilateral agreements, each with a different set of member countries.

Each of the six agreements was negotiated within – and is now administered by – an international organization. Four of the six are managed by the World Intellectual Property Organization (WIPO); one by the United Nations Educational, Scientific and Cultural Organization (UNESCO); and one by the World Trade Organization (WTO).

All six agreements have been created and implemented in similar ways. Typically, the process begins when representatives of countries think that there should be international standards governing a set of issues. They enter into negotiations, which can last several years. During the negotiations, draft provisions are presented to the delegations of each country, which then discuss them and may propose amendments to their content. Once consensus has been reached, the countries conclude the treaty by signing it. Thereafter, the governments of the participating countries ratify the treaty, whereupon it enters into force. From that moment onward, the signatory countries assume obligations towards the other countries to implement the international agreement. Countries that did not sign the treaty when it was initially concluded may join the treaty later by accession.

None of the six treaties contains a comprehensive set of rules or standards for a copyright system. Rather, each one requires member countries to deal with particular issues in particular ways, but leaves to the member countries considerable discretion in implementing its requirements. Nor do any of the treaties bind individual persons within the member countries until and unless the governments of those countries actually implement the standards with legislation.

Click here for more on the stages of an international agreement.

Set forth below are brief descriptions of the six major treaties, with special attention to their impacts on developing countries.

Berne Convention

The uncertainty and confusion arising from the lack of a unified framework for the protection of copyright led ten European States in 1886 to sign the Berne Convention for the Protection of Literary and Artistic Works (henceforth Berne Convention). Since then, a total of 164 countries have joined the Berne Convention. However, there have been several revisions of the Berne Convention, and not all countries have ratified the most recent version. Any nation is permitted to join. You can easily check to see if your country is a member of the Berne Convention. Below is a map showing which countries are currently members.

The Berne Convention established three fundamental principles. The first and most famous is the principle of “national treatment,” which requires member countries to give the residents of other member countries the same rights with respect to copyright law that they give to their own residents. So, for example, a novel written in France by a French citizen enjoys the same protection in Italy as a novel written in Italy by an Italian citizen.

The second is the principle of “independence” of protection. It provides that each member country must give foreign works the same protections they give domestic works, even when the foreign works would not be shielded under the copyright laws of the countries where they originated. For example, even if a novel written in Belgium by a Belgian national were not protected under Belgian law, it would still be protected in Italy if it fulfilled the requirements for protection under Italian law.

The third is the principle of “automatic protection.” This principle forbids member countries from requiring compliance with legal formalities as a prerequisite for copyright protection. In other words, in Berne Convention countries, original works enjoy copyright protection automatically from the moment they are created. So, for example, the British author of a novel doesn’t have to register or declare her novel in France, Italy, Belgium or any other member state of the Berne Convention; her novel will be automatically protected in all of these countries from the moment it is written.

In addition to these basic principles, the Berne Convention also imposes on member countries a number of more specific requirements. For instance, they must enforce copyrights for a minimum period of time. The minimum copyright term for countries that have ratified the most recent version of the Berne Convention is the life of the author plus 50 years for all works except photographs and cinematic works. The Convention also requires its members to recognize and enforce a subset of the “moral rights” discussed in Module 1: Copyright and the public domain: an introduction.

The Berne Convention sets forth a framework for member countries to adopt exceptions to the mandated copyright protections. Article 9(2) sets forth what it widely known as the “three-step test.” Article 9(2) provides that member nations may provide statutory exceptions as long as the exceptions (1) are for “special cases,” (2) do not “conflict with a normal exploitation” of the copyrighted work, and (3) do not “unreasonably prejudice” the author's “legitimate” interests. Other provisions of the Berne Convention give member countries discretion to create more specific exceptions.

When the Berne Convention was revised most recently in Paris in 1971, the signatory countries added an Appendix, which contained special provisions concerning developing countries. In particular, developing countries may, for certain works and under certain conditions, depart from the minimum standards of protection with regard to the right of translation and the right of reproduction of copyrighted works. More specifically, the Appendix permits developing countries to grant non-exclusive and non-transferable compulsory licenses to translate works for the purpose of teaching, scholarship or research, and to reproduce works for use in connection with systematic instructional activities.

While the Berne Convention outlines broad standards for copyright protection, it mandates few specific rules. As a result, each national legislature enjoys considerable flexibility in implementing the Berne Convention. For example, in the Berne Convention Implementation Act of 1988, the U.S. Congress adopted a “minimalist” approach to implementation, making only those changes to copyright law that were absolutely necessary to qualify for membership.

Furthermore, at the time that the Berne Convention was signed, the signatory countries did not establish an enforcement mechanism. This meant that member states had little power to punish another state that did not abide by the Berne Convention's guidelines. As we will see later on, this situation partially changed for the members of the Berne Convention that also joined the World Trade Organization.

To learn more about the Berne Convention you may read its text or review the provisions of the Berne Convention.

Rome Convention (1961)

By 1961, technology had progressed significantly since the Berne Convention was signed. Some inventions, such as tape recorders, had made it easier to copy recorded works. The Berne Convention only applied to printed works and thus did not help copyright holders defend against the new technologies. To address the perceived need for strong legislative protection for recorded works, the Rome Convention for the Protection of Performers, Producers of Phonograms and Broadcasting Organizations was concluded by members of WIPO on October 26, 1961. It extended copyright protection from the author of a work to the creators and producers of particular, physical embodiments of the work. These "fixations" include media such as audiocassettes, CDs, and DVDs.

The Rome Convention requires member countries to grant protection to the works of performers, producers of phonographs, and broadcasting organizations. However, once a performer has consented to the incorporation of her performance in a visual or audiovisual fixation, the provisions on performers’ rights have no further application. Equally important, the Convention allows member countries to create certain exceptions to the rights of performers, producers of phonographs, and broadcasting organizations – for example, to permit unauthorized uses of a work for the purpose of teaching or scientific research.

86 countries have signed the Rome Convention. Below is a map of the member states of the Rome Convention:

Membership in the Rome Convention is open only to countries that are already parties to the Berne Convention or to the Universal Copyright Convention. Like many international treaties, joining the Rome Convention has an uncertain effect on domestic law. Countries that join the convention may "reserve" certain rights with regards to certain provisions of the treaty. In practice, this has enabled countries to avoid the application of rules that would require important changes to their national laws.

For more information on the Rome Convention you may read its text or read more about the Rome Convention provisions.

WIPO Copyright Treaty (WCT)

The way that copyright holders reproduce, distribute, and market their works has changed in the digital age. Sound recordings, articles, photographs, and books are commonly stored in electronic formats, circulated via the Internet, and compiled in databases. Unfortunately, the same technologies that enable more efficient storage and distribution of works also facilitate widespread copyright infringement. In order to protect copyright in the new technological era and to combat what has come to be called (misleadingly) “electronic piracy,” the governments of developed countries advocated for and ultimately secured two treaties: the WIPO Copyright Treaty and the WIPO Performance and Phonograms Treaty.

The WIPO Copyright Treaty (WCT) is a special agreement under the Berne Convention that entered into force on March 6, 2002. It is the first international treaty that requires countries to provide copyright protection to computer programs and to databases (compilations of data or other material).

The WCT also requires members to prohibit the circumvention of technologies set by rightsholders to prevent the copying and distribution of their works. These technologies might include encryption or “rights management information” (data that identify works or their authors, and that are necessary for the management of their rights).

70 countries are party to the WCT. Below is a map of the member states:

For more about the WCT read its text or read the Examination of the WCT.

WIPO Performances and Phonograms Treaty (WPPT)

The WIPO Performances and Phonograms Treaty (WPPT) was signed by the member states of WIPO on December 20, 1996. WPPT enhances the intellectual property rights of performers and of producers of phonograms. Phonograms include vinyl records, tapes, compact discs, digital audiotapes, MP3s, and other media for storing sound recordings.

The WPPT grants performers economic rights in their performances that have been fixed in phonograms. It also grants performers moral rights over these performances. By contrast, the producers of phonograms are only granted economic rights in them.

Both the WCT and the WPPT (like the TRIPS Agreement, which we will consider shortly) require members to quickly adopt and enforce the provisions of the treaty.

68 countries are party to the WPPT. Below is a map of the member countries:

For more about the WPPT read its text or consult the Examination of the WPPT.

Universal Copyright Convention

The Universal Copyright Convention (or UCC) was developed by UNESCO and adopted in 1952. It was created as an alternative to the Berne Convention. The UCC addressed the desire of several countries (including U.S.A. and the Soviet Union) to enjoy some multilateral copyright protection without joining the Berne Convention.

The UCC’s provisions are more flexible than those of the Berne Convention. This increased flexibility was intended to accommodate countries at different stages of development and countries with sharply different economic and social systems. It incorporates the principle of national treatment and prohibits any discrimination against foreign authors.

The UCC has decreased in importance as most countries are now party to the Berne Convention and/or members of the World Trade Organization (WTO). The copyright obligations of members of the WTO are governed by the Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS), discussed below.

You may check if your country is a member of the UCC by reviewing this list. For more information about the UCC you may read its text or consult the Examination of the UCC.

The Agreement on Trade Related Aspects of Intellectual Property Rights (TRIPS)

The Agreement on Trade Related Aspects of Intellectual Property Rights (TRIPS) is an international agreement administered by the World Trade Organization (WTO). The TRIPS agreement was negotiated and concluded in 1994. TRIPS establishes minimum standards for many forms of intellectual property protection in member countries, including copyright.

The substantive provisions of TRIPS do not differ significantly from the Berne Convention. The major difference is that TRIPS requires member countries to protect computer programs and data compilations. However, TRIPS does not mandate the protection of authors' moral rights, which the Berne Convention requires.

The most important innovations of TRIPS are the remedies it requires. First, unlike Berne, TRIPS requires member countries to provide effective sanctions for violations of copyrights. Second, it creates a dispute resolution mechanism by which countries can force other members to comply with their treaty obligations. It might be said that, unlike the Berne convention, TRIPS has teeth.

As with all copyright law, TRIPS attempts to strike a balance between the public's interest in free expression and the rights of copyright holders. TRIPS allows member states to establish limitations and exceptions to the rights of copyright holders if they meet the requirements of the three step test originally introduced in the Berne Convention. TRIPS contains one modification to the language of the three step test, however. Specifically,l the third prong of the TRIPS three part test requires any exceptions to avoid unreasonably prejudicing the copyright holder's legitimate interests, while the Berne Convention mentions only the legitimate interests of the author. You can read more information concerning the three-step test.

Finally, TRIPS allows for some flexibility in its implementation. This flexibility is intended to permit developing nations to balance the incorporation of the general principles of TRIPS with development concerns. You can study additional Information concerning the flexibilities of TRIPS for developing nations.

For more about TRIPS you may read its text or consult the Examination of the TRIPS provisions.

The proposed Anti-Counterfeiting Trade Agreement (ACTA)

These six multilateral treaties may soon be joined by a seventh. In October 2007, the United States, the European Community, Switzerland, and Japan simultaneously announced that they would negotiate a new intellectual property enforcement treaty, the Anti-Counterfeiting Trade Agreement (ACTA). Australia, the Republic of Korea, New Zealand and Mexico have since joined the negotiations. Several rounds of negotiations have occurred. Participants have stated publicly that they expect to finish negotiations in 2010.

Among other issues, ACTA will contain provisions to address "Internet distribution and information technology," such as authorizing officials to search for illegally downloaded music on personal devices at airports, or forcing Internet Service Providers to provide information about possible copyright infringers without a warrant.

Regional Agreements

The multilateral agreements we have just described contain the primary provisions that limit the freedom of each country in shaping its own copyright laws. But some countries also belong to regional organizations that have the power to influence the copyright laws of their member countries. The most important such regional organization is the European Union, commonly known as the EU. Beginning in 1991, the EU has adopted several Directives relating to copyright law. (A directives obliges the member countries to bring their laws into conformity with its requirements by a particular date, but leaves to each country's discretion some flexibility in achieving that goal.) For example, the Software Directive required member countries to grant copyright protection to the authors of software programs, regardless of how creative those programs are. The Rental Rights Directive required member countries to recognize "a right to authorize or prohibit the rental and lending of originals and copies of copyright works...." The Copyright Directive of 1993 required member countries, among other things, to extend copyright protection to the life of the author plus 70 years. The highly controversial Information Society Directive was adopted in 2001 to implement the WIPO Copyright Treaty, discussed above. (The main provisions of the Copyright Directive will be discussed in subsequent modules.) And the Resale Rights Directive obliges member countries to grant the creators of original works of art a right to remuneration when those works are resold.

The North American Free Trade Agreement (NAFTA), which was entered into in 1994 by Canada, the United States, and Mexico, also limits the discretion of those three countries in defining their intellectual-property laws. However, with respect to copyright laws in particular, NAFTA closely parallels the TRIPS Agreement, discussed above, and thus has relatively little independent significance.

Other regional organizations that could influence their member countries' copyright systems -- but that have not yet, for the most part, done so -- include The Andean Community (Bolivia, Colombia, Ecuador, and Peru), Mercosur (Argentina, Brazil, Paraguay, Uruguay, and (perhaps soon) Venezuela), the African Regional Intellectual Property Organization (ARIPO) (Botswana, the Gambia, Ghana, Kenya, Lesotho, Malawi, Mozambique, Namibia, Sierra Leone, Somalia, Sudan, Swaziland, Tanzania, Uganda, Zambia, and Zimbabwe), the African Intellectual Property Organization (OAPI) (Benin, Burkina Faso, Cameroon, Central Africa, Congo, Cote d'Ivoire, Equatorial Guinea, Gabon, Guinea, Guinea Bissau, Mali, Mauritania, Niger, Senegal, Chad, and Togo).

Free Trade Agreements and Bilateral Investment Treaties

Multilateral treaties such as TRIPS can provide powerful global protection for copyright holders because they establish minimum standards for protection of copyrights that are binding on large numbers of countries. However, they do not eliminate the incentives for bilateral treaties between countries or organizations of countries. Bilateral treaties on copyright law often address specific issues between the the two parties. Such agreements are commonly known as free trade agreements (FTAs) or Bilateral Investment Treaties (BITs).

Typically, such bilateral agreements either narrow the flexibilities that a developing country would enjoy under TRIPS or impose more stringent standards for copyright protection. For example, the US government has included anti-circumvention obligations in its bilateral FTAs with Jordan, Singapore, Chile, Morocco, Bahrain and Oman.

Click here for more Information on FTAs.

Perspectives For Developing Countries

The Benefits and Drawbacks of Copyright Law for Developing Countries

Some believe that governments should upgrade and harmonize copyright law globally because it promotes the arts and rewards creators. They argue that granting an exclusive right in creative expression provides a necessary incentive for copyright holders to invest in the creation and distribution of expressive works. This stimulates cultural expression and benefits citizens.

However, others argue that implementing the same copyright law in all countries has a disproportionate and negative effect on developing countries. Most developed nations have powerful and lucrative entertainment, educational, and research industries that export copyrighted works, and thus benefit from strong copyright law. Developing countries, on the other hand, typically import copyrighted works. Thus, it is argued, the residents of developing countries have to pay more royalties and fees as a result of enhanced copyright protection. It is also argued that restrictive copyright laws prevent many governments from fulfilling important human rights obligations - such as providing educational resources - because critical information is locked up by the law.

The latter set of arguments have has prompted a growing number of groups in developing countries to resist the imposition of the minimum standards of copyright protection set by the TRIPS agreement and the even harsher duties that are imposed on developing countries by FTAs. They call for a better balance between, on one hand, providing incentives to creators and rewarding their creative activities and, on the other hand, promoting access to knowledge and research, in order to spur economic growth and foster innovation in the developing countries.

WIPO Development Agenda

The WTO has entered into an agreement with WIPO to provide advice to developing countries on the implementation of TRIPS. Some in developing countries consider the advice provided by WIPO to be too weighted in favor of the rights of copyright holders. In 2004, Brazil and Argentina submitted to the WIPO General Assembly a proposal for a “development agenda.” The proposal called on WIPO to pay greater attention to the impact of intellectual property protection on economic and social development, the need to safeguard flexibilities designed to protect the public interest, and the importance of promoting “development oriented” technical cooperation and assistance. Additional proposals in support of a WIPO Development Agenda were submitted by other member countries and organizations, such as Chile, the Group of Friends of Development, and the Africa Group.

This initiative has made considerable progress. The 2004 WIPO General Assembly agreed to hold a series of intergovernmental meetings to examine the proposals for a development agenda. Substantive reform proposals to establish a development agenda for WIPO passed during the 2007 WIPO General Assembly. The current WIPO Development Agenda contains 45 recommendations for the General Assembly to pursue.

Organizations representing librarians have had a significant voice in the negotiations of the WIPO Development Agenda. Joint statements of the International Federation of Library Associations (IFLA), the Library Copyright Alliance (LCA), and Electronic Information for Libraries (eIFL) are available here. Click here for more information on the WIPO development agenda.

The Proposed Access to Knowledge (A2K) Treaty

The Argentina-Brazil proposal for a development agenda prompted a debate on whether WIPO should ensure effective technology transfer from developed to developing countries. Nongovernmental organizations (NGOs), academics, and researchers shared the concerns expressed by developing countries that aspects of the copyright system were actually impeding innovation and creating disadvantages for developing countries. This reaction to WIPO’s current policies took the form of a movement calling for equality among citizens from developed and developing countries as regards access to knowledge; it has come to be known as the “access to knowledge” or “A2K” movement. Librarians’ organizations, such as eIFL, were pioneers in the advocacy of a “right to knowledge” and have called upon WIPO to establish minimum exceptions and limitations to copyright protection.

One outgrowth of the movement has been a proposal for a United Nations treaty. The proposed treaty intends to “protect and enhance access to knowledge, and to facilitate the transfer of technology to developing countries.” It includes a list of exceptional circumstances under which copyright holders may not prevent the free use of their content, including:

• The use of works for purposes of library or archival preservation, or to migrate content to a new format.
• The efforts of libraries, archivists, or educational institutions to make copies of works that are protected by copyright but that are not currently the subject of commercial exploitation, for purposes of preservation, education, or research.
• The use of excerpts, selections, and quotations from copyrighted works for purposes of explanation and illustration in connection with not-for-profit teaching and scholarship.
• The use of copyrighted works by educational institutions as primary instructional materials, if those materials are not made readily available by copyright holders at a reasonable price.

In addition, the proposal advocates a First Sale Doctrine for Library Use, stating that “a work that has been lawfully acquired by a library may be lent to others without further transaction fees to be paid by the library.” Finally, the A2K treaty proposal introduces provisions in support of distance education, as well as provisions accommodating the rights of persons with disabilities.

Librarians and library patrons aren’t the only parties who could benefit from the A2K treaty. The proposal includes rules protecting Internet Service Providers from copyright liability, and also mitigates the strict circumvention prohibitions contained in the international copyright treaties. Under the proposed treaty, Nonoriginal and orphan works (those works for which a copyright holder cannot be identified upon reasonable search) would be left in the public domain. The treaty would also guarantee access to publicly funded research works, government works, and archives of public broadcasting. Finally, the A2K treaty proposal also includes provisions on patent protection, anticompetitive practices, and transfer of technology to developing countries.

Click this link for additional information on the A2K Treaty proposal.

Back to the Case Study

Nadia knows that Mexico is a member of the Berne Convention, Rome Convention, WCT and WPPT. Mexico is also a member of the WTO, and thus bound by the provisions of TRIPs. After checking the online databases provided on the WIPO website she discovered that:

• Ethiopia isn’t a member of any of the international treaties on copyright protection. Thus, the national government of that country regulates copyright differently than the rest of the world. Therefore Nadia must separately study Ethiopian copyright law.
• Russia has signed the Berne Convention as well as the Rome Convention, but isn’t yet a member of the WTO and accordingly is not bound by TRIPS. Neither the Berne Convention nor the Rome Convention have a mechanism for other countries to challenge a member's implementation of its treaty obligations. Furthermore, the Rome Convention allows countries to make reservations with regard to the application of certain provisions, so Russia may not have implemented all of the treaty provisions. In addition, Russia has signed the WCT, but the treaty hasn’t yet entered into force in Russia. In other words, although Russia has signed the treaty, it hasn’t yet been incorporated into Russian law, and thus does not bind Russian citizens. Russia also isn’t a member of the WPPT.
• India is a party to the Berne Convention and the Rome Convention and is also a member of the WTO. As a member of the WTO, India is bound by the TRIPS Agreement. TRIPS requires WTO members to comply with the substantive provisions of the Berne Convention, with the exception of the recognition of moral rights. Therefore, Nadia can rely on the fact that the substantive requirements for copyright protection in Mexico and India are similar. However, India hasn’t signed the WCT and the WPPT. Thus, Nadia would have to consult Indian copyright law to determine how it regulates copyright protection of computer programs and databases and the rights of performers and of producers of phonograms.
• Finally Belgium is a member of all of the international treaties on copyright protection discussed above. Thus, Belgian copyright law is likely to be similar to Mexican copyright law in many respects.

As a result, Nadia can only apply for the exchange program in Belgium, as she knows the basic framework for copyright protection in Belgium, based on her knowledge of Mexican copyright law.

Assignment and discussion questions

Assignment

1. Which international treaties governing copyright law has your country signed, ratified, and implemented?

2. If your country is a member of the Berne Convention, may your national legislature freely set the copyright term to either a) 120 years or b) 25 years? Why or why not?

3. Imagine that your country is a member of the Berne Convention, but not of the WTO. Thus, your country is not bound by TRIPS.

• May your national legislature require foreign copyright holders to register their works with your country in order to receive copyright protection?
• If your legislature did require registration, could other members of the Berne Convention take action against your country? How would your answer be different if your country was also a member of the WTO?

4. Imagine that both your country and the fictional country of Atlantis are members of the Rome Convention. Could your legislature allow music teachers in your country to freely use recordings of Atlantean singers in their classes? Could Atlantis demand that your legislature require the music teachers to compensate the Atlantean singers?

5. Atlantis has recently signed and ratified the WIPO Copyright Treaty. Its national legislature wants to implement the treaty. Atlantis only imports software from other countries and it has never before protected them under copyright law. The legislature believes that it is in the interest of Atlanteans to extend as little copyright protection to computer programs as possible. What provisions of the WTC would allow Atlanteans to freely use computer programs?

6. What do you consider to be the advantages and the disadvantages of enhanced copyright protection for creative works?

7. Do you think that both developed and developing countries should have the same rules for copyright protection? Why or why not?

8. Read article 3-1 of the draft text of the A2K treaty. Comment on the importance of one or two provisions for the missions you perform as a librarian.

Discussion Question(s)

Please read the comments on the A2K treaty proposals that your colleagues provided to Round 1 question 8, and comment on one (or more) of them. You may give more examples based on situations you have faced at work, or projects you could develop.

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