20 July 2013

Lithuania And Estonia Use Google Maps Street View To Catch Tax Cheats

As we've noted before, the information captured by Google's Street View has been put to some surprising uses, and the Boston Globe has come across a further fascinating example from Lithuania

On Techdirt.

Cambodian Activists Explain Why The EU-India FTA Is A Matter Of Life And Death

One of the many problems with the secretive nature of trade agreements is that it insulates negotiators from the real-world consequences of their actions. That's particularly true for the FTA talks between the EU and India, currently taking place behind closed doors. One of the key issues for the EU side is India's role as a supplier of generic medicines to the world, and India's tough stance on issues like the evergreening of pharma patents. From the various leaks that we have, it seems that the EU is demanding that India toe the line on drug patents, and cut back its supply of low-cost generics to emerging countries. 

On Techdirt.

The Free, Open Web: 20 Years of RF Licensing

As regular readers of this column know, there's still a battle going on over whether standards should be FRAND or restriction/royalty-free (RF). The folly of allowing standards to contain FRAND-licensed elements is shown most clearly by the current bickering between Microsoft and Google. What makes that argument such a waste of time and money is the fact that for 20 years we have had the most stunning demonstration of the power of RF:
 

European Commission Replies to My IPRED Letter

Earlier this month I wrote a couple of posts about a letter I sent off to the European Commission concerning my appalling experience with the IPRED consultation. Well, I now have a reply, which I reproduce below:

On Open Enterprise blog.

Please Write to MEPs *Now* about TAFTA/TTIP

Sorry to trouble you again this week, but there's an important vote in INTA today (25 April) on the transatlantic trade agreement (TAFTA/TTIP), and there are some crucial issues that you might like to convey to your MEP, especially if they are on the INTA committee. 

On Open Enterprise blog.

Please Write to Your MPs About Snooper's Charter

It seems that the UK government will be deciding what to do about the Snooper's Charter this week. It is already under huge pressure as more and more problems with the plans become evident. I urge you to write to your MP (perhaps using WriteToThem.com) to express your own concerns.

On Open Enterprise blog.

Clinical Trials Must be Open Data: Please Contact MEPs

Back in February, I noted that the UK's investigation into making clinical trial data freely available was somewhat subsidiary to the EU's major initiative on the same subject. The battle there between those who wish to keep clinical trials data secret, for fear that it might show pharma companies in a bad light, and those who believe that it must be released to save money and - more importantly - save lives is now increasingly fierce.

On Open Enterprise blog.

Software Patents Storming Up the Agenda Again

As regular readers of this column will know, software patents have never really gone away, even though the European Patent Convention forbids them, and the European Parliament explicitly rejected them again in 2005. Fans of intellectual monopolies just keep coming back with new ways of getting around those bans, which means that the battle to stop them crippling the European software industry has to be fought again and again.

On Open Enterprise blog.

Why CISPA Shows We Need Strong EU Data Protection

It seems hard to believe that it was only a little over a year ago that the threat from the US SOPA (Stop Online Piracy Act) was averted (and that ACTA was still with us in the EU). But of course the war is never won: new threats to freedom and openness on the Internet just keep on coming. 

On Open Enterprise blog.

The Future of Commercial Open Source: Foundations

Remember MySQL? Most famous for being part of the LAMP stack, and thus powering the bulk of the innovative work done in the field of ecommerce for a decade or more, it's rather fallen off the radar recently. It's not hard to see why: Oracle's acquisition of Sun, which had earlier bought MySQL for the not inconsiderable sum of $1 billion, meant that one of the key hacker projects was now run by the archetypal big-business mogul, Larry Ellison. So it was natural that people were unsure about MySQL's future, and started looking for alternatives.

On Open Enterprise blog.

'Intellectual Bulwark' Of Austerity Economics Collapses Because Of Three Major Errors

Amongst economists and those who draw on their thinking, the names Reinhart and Rogoff are well known for work published under the title "Growth in a Time of Debt," which sought to establish the relationship between public debt and GDP growth. The key result, that median growth rates for countries with public debt over 90% of GDP are about one percent lower than otherwise, and that the mean growth rate is much lower still, has been cited many times, and invoked frequently to justify austerity economics -- the idea being that if the public debt is not reduce, growth is likely to suffer badly. 

On Techdirt.

UK Supreme Court Says Unauthorized Browsing Of Copyright Material Online Is OK, But Asks European Court Of Justice Just In Case

The lawsuits brought against the media monitoring firm Meltwater in both the US and the UK have not turned out too well for the company so far. In the US, the district court handed down a summary judgment against Meltwater, while in the UK, two courts came to a particularly worrying conclusion: that simply viewing copyright material online without a license amounted to infringement. 

On Techdirt.

Argentine Judge Says Community Rights To Access Works Can Outweigh Creator's Moral Rights

Even though they don't figure much in the US legal landscape, moral (non-economic) rights such as the right of attribution are an important aspect of copyright law in many other countries. Intellectual Property Watch has a fascinating account of a case from Argentina, where a judge decided that an individual's moral rights could be overridden by the rights of the community

On Techdirt.

Western Publishers Sue Delhi University Over Photocopied Textbooks; Students And Authors Fight Back

Back in October last year, we wrote about Costa Rican students taking to the streets to defend their right to photocopy otherwise unaffordable university textbooks. Of course, that's not just a problem in Costa Rica: in many parts of the world, high prices act as a significant barrier to education, and it will come as no surprise that photocopying is an accepted practice in many countries. 

On Techdirt.

Investor-State Dispute Resolution: The Monster Lurking Inside Free Trade Agreements

We wrote recently about how multilateral trade agreements have become a convenient way to circumvent democratic decision making. One of the important features of such treaties is the inclusion of an investor-state dispute resolution mechanism, which Techdirt discussed last year. The Huffington Post has a great article about how this measure is almost certain to be part of the imminent TAFTA negotiations, as it already is for TPP, and why that is deeply problematic: 

On Techdirt.

When Is An Image 'Manipulated Enough' To Become An Original Creation?

Images manipulated using programs like Photoshop or the GIMP are a familiar sight online. Indeed, the ease with which images can be modified has led to an amazing flowering of this new branch of the visual arts. But like much in the digital world, this brings with it problems. Here, for example, is the interesting case of a competition on the MINI Space site, which is run by BMW as an oblique form of marketing for its Mini car. An article on the PetaPixel photography blog explains what happened when the site invited submissions on the theme of "check-mate" (pointed out to us by @copyrightgirl). Here's "PapiloChessBoard", the photomanipulated image that gained the winner a MacBook Pro laptop: 

On Techdirt.

http://blogs.computerworlduk.com/open-enterprise/2013/04/italys-big-leap-forward-for-openness/index.htm

A few weeks ago, I wrote of the continuing progress on the central Gov.uk site, which is a showcase of open technologies, as well as being the place to start when interacting with central government in the UK. Looks like I'm not the only one who is impressed by their work, since the site has just been chosen as Design of the Year in the Design Museum's

On Open Enterprise blog.

Italy's Great Leap Forward for Openness?

Different countries are moving at different speeds in terms of governmental adoption of free software, open data and openness in general. I wrote a year ago about Iceland, which seemed to be making particularly rapid progress at the time. Now it looks like it's Italy's turn. 

On Open Enterprise blog.

How Big Agribusiness Is Heading Off The Threat From Seed Generics -- And Failing To Keep The Patent Bargain

Recently we wrote about how pharmaceutical companies use "evergreening" to extend their control over drugs as the patents expire. But this is also an issue for the world of agribusiness: a number of key patents, particularly for traits of genetically-engineered (GE) organisms, will be entering the public domain soon, and leading companies like Bayer, BASF, Dow, DuPont, Monsanto and Syngenta are naturally coming up with their own "evergreening" methods. 

On Techdirt.

05 July 2013

Birth of a Meme: the Tweetlog

As some of you may know, alongside this blog here - a slightly empty place at the moment, for which apologies - I run something called rather grandly "Moody's Microblog Daily Digest".  This is simply a collection of most of my tweets for each day - discarding the ephemeral ones that are replies etc.

It's mainly so that I have a readily-accessible store of them that is independent of Twitter, and that I can search through easily since Twitter's search is pretty feeble (hint, hint...).

Now I see that Björn Brembs has started doing the same on his blog.  He's dubbed it a "tweetlog", which seems a pretty good description.  What do people think?  Is this the birth of meme?

15 June 2013

Glyn Moody's PGP Key

In the light of, er, recent events, I've decided to up my crypto game - I now encourage people to use PGP when emailing me. Here's my public key (also available on public key servers such as http://kerckhoffs.surfnet.nl/):
 
-----BEGIN PGP PUBLIC KEY BLOCK-----
Version: GnuPG v1.4.12 (GNU/Linux)

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eW4ubW9vZHlAZ21haWwuY29tPokBPgQTAQIAKAUCUaEOwQIbIwUJCWYBgAYLCQgH
AwIGFQgCCQoLBBYCAwECHgECF4AACgkQrmu000rVU2GGmgf+KDWRTSZ90kzJwdfp
byrx4kwdU6ZrxZyyKFvatdn8s23zA6cenwV34j+BUYHbwAoq1rpaLoR2aCgpXSUb
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2f7YyGlRsW+/1pxAOJqfPqYQ61OCTHTzY+NTQVn/b+82BL+y4GBK0iND+SLX7RUU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rN8vrhlZP3MgcNaXeN6+pfw7ROf53baE6qJ0smonwyoUwHD8ewFEpFUqwEcIohh+
QTlhisqjyOT9BgzOIjqbbNSkImaN68q6Z7ChiDVe07FDhbIgZXFhimP9nx8jvfrB
x6iWQeeCqOpWXOCzQDIUgMwsW6UGxRnaA3AsQzMh3uCvzdNmTJdCwW6Ek16Feac5
3YO3YDOzxC1+HftgvxfD5Yu8/7vOh//DCZTUQGzNZ9NCPaaa7mCeOp+dDfY=
=wFDl
-----END PGP PUBLIC KEY BLOCK-----
I don't use any other PGP keys you may come across. If that changes, I'll post about it. Other updates on how I'm trying to make things more interesting for certain people (</waves at NSA>) will follow in due course.

02 June 2013

Watch Out for the Coming TAFTA/TTIP "Science-Based" Negotiating Trick [Updated]

As anyone who has been following me recently will know, one of the most important geopolitical developments is the decision to negotiate a Transatlantic Free Trade Agreement (TAFTA), also known as the Transatlantic Trade and Investment Partnership (TTIP), which makes clear its kinship with the Trans-Pacific Partnership Agreement (TPP) currently being drawn up.

Equally, you will know that my chief concern with TAFTA/TTIP is not so much any section on intellectual monopolies - although those might well turn out to be ACTA 2.0 - but the clauses dealing with unmemorably-named "Investor State Dispute Resolution".

I've explained what these are and why they are so dangerous on Techdirt (twice, actually.)  In a sentence, this system allow a company to sue a country, directly, for alleged loss of future profits caused by tiresome things like environmental legislation or health and safety laws.

These kind of disputes are also moving into the area of intellectual monopolies - for example, Canada is being sued by Eli Lilly for refusing to grant a patent on one of its drugs.  Worryingly, the European Commission mandate to its negotiators for TAFTA/TTIP explicitly allows precisely this kind of action.

However, here I want to concentrate on another aspect of TAFTA/TTIP: how the term "science-based" will be used in an attempt to ram through a range of spectacularly unscientific approaches that are currently allowed in the US, but not in Europe.

Here's what an article on the subject says:

To export agricultural goods, the U.S. also exports food safety standards, or at least gets other countries to accept our way of growing raw materials and processing them into food as justified by standards “based on science.” The U.S. Department of Agriculture and the U.S. Trade Representative will soon see if the member governments of the Trans Pacific Partnership (TPP) and the Transatlantic Trade and Investment Partnership (TTIP) negotiations, launched by the Obama administration, will accept the way U.S. chicken processors butcher the bird. A National Chicken Council press release welcomed the launch of the TTIP negotiations: “When TTIP negotiations are successfully concluded, U.S. poultry producers look forward to marketing $500 million of products to the EU on an annual basis.”
 The article is principally about the following incident:

The death of a U.S. federal poultry inspector, reported on April 25 in the Washington Post, shone a bright light on the high speed processed, chlorine rinsed chicken that the U.S. wants to export not just to the EU, but globally. The inspector, 37 year old José Navarro, worked for five years in the midst of a chemical spray that the USDA allows processors to use to decontaminate the feces on chickens that results from ever faster processing line speeds. Navarro’s lungs bled out. The U.S. Occupational Health and Safety Commission (OSHA) has not determined the cause of Navarro’s bleeding to death. An OSHA spokesperson said the agency was so understaffed, it would take 131 years to inspect every facility under its authority for worker safety violations.
That hardly inspires confidence in the substance being sprayed on the chickens.  So a legitimate question is: how do we know that it's safe?
Both the USDA and the National Chicken Council (NCC) defended the use of the poultry rinse, pointing out that the Food and Drug Administration had accepted the poultry industry’s claim that the rinse was Generally Recognized As Safe (GRAS). GRAS is only a food safety designation, not a worker safety rule. Stan Painter, the president of the federal meat and poultry inspectors union, said his poultry inspectors reported weekly about coughing, sneezing, tight throats and itchy eyes that clear up only on the weekends when they are not working. However, “based on science” standards only protect traded goods, not the workers who produce them.
Here's some more information on that "Generally Recognised As Safe" idea from the US Food and Drug Administration site:

For a food additive, privately held data and information about the use of a substance are sent by the sponsor to FDA, which evaluates those data and information to determine whether they establish that the substance is safe under the conditions of its intended use (21 CFR 171.1). Thus, for a food additive, FDA determines the safety of the ingredient; whereas a determination that an ingredient is GRAS can be made by qualified experts outside of government.
Here's how much scrutiny the FDA gives:

Within 30 days of receiving a notice FDA will inform the notifier in writing of the date on which the notice was received. FDA then evaluates whether the submitted notice provides a sufficient basis for a GRAS determination and whether information in the notice, or otherwise available to FDA, raises issues that lead the agency to question whether use of the substance is GRAS.

So, basically, chlorine rinse for chickens, that may well have caused an operator's lungs to bleed until he died, has been approved because the manufacturer says it's checked, and everything's OK.  This is the "science-based" approach that US negotiators will invoke when negotiating with the EU in an attempt to force chlorine-soaked chickens on European consumers.

Nor will it stop there.  Another hugely contentious area is, of course, genetically-modified food.  Here, too, self-certification is essentially all the US has to justify approval:

Under U.S. regulations, biotech companies are not required to submit studies to demonstrate the safety of their products. The companies voluntarily submit only summaries of data vetted by company risk managers and without the methodological explanations of the studies that permit the peer review that is characteristic of scientific method.

What US companies really mean by "science-based" in this context is illustrated by the following:

Monsanto is threatening the European Food Safety Authority (EFSA) with legal action after the European Union’s central science agency published data relating to a Monsanto genetically modified (GM) maize form.

This was data submitted to establish that the GM maize was not harmful - in other words, basic scientific data required for approval.  And yet Monsanto was threatening the EFSA for daring to reveal those basic facts.

That shows what US companies mean by "science-based": that they get to make claims about their products that others are not allowed to check.  But the essence of "science-based" is that others can and *must* be able to check the results claimed.  The use of the impressive-sounding "science-based" argument turns out to be a sham - simply a way of browbeating legitimate concerns about health and safety.

If companies truly believed in "science-based" approaches, they would freely release all their safety data, and would encourage independent third-parties to check their validity.  But that won't ever happen, because the invocation of "science-based" is pure bluster.

So watch out for the use of "science-based" arguments during the coming TAFTA/TTIP: I predict it's a phrase we'll being hearing a lot of, soon.  And when you hear it, remember that it's just a shabby negotiating trick that sullies the good name of science.

Update: As I predicted, "science-based" approaches are at the heart of TTIP.  And here is how the European Commission is using the underhand trick I outlined above:

Monsanto and the pesticide industry breathed a collective sigh of relief on 12 November 2015. The findings of an investigation into the toxicity of glyphosate by the European Food Safety Authority (EFSA) and EU Member States were in stark contradiction to the March 2015 conclusion by the International Agency for Research against Cancer (IARC), a body of the World Health Organization (WHO), that this agricultural herbicide was probably causing cancer to humans. If validated, this conclusion could cause a partial ban of glyphosate in the EU.

This article takes a closer look at the arguments from both parties, and reveals two strikingly different processes that led to these conflicting assessments. In short, the WHO process was transparent, stuck to conventional scientific methodology and looked at glyphosate-containing herbicides (as glyphosate is never used alone in the real world), whereas EFSA's route was based on a 'peer review' by anonymous EFSA and national public officials relying on undisclosed industry-sponsored studies that looked at glyphosate alone. The European Commission, which will have the last say on whether or not glyphosate will be re-authorized in the EU, and under which conditions, must now decide what to make of this interesting piece of 'science'.

It's not hard to guess which kind of "science" they will choose...

17 May 2013

Why are Facebook, IBM, Microsoft and Oracle Backing the Fight *Against* the Blind?


One of the more disgraceful examples of the inherent selfishness of the copyright world is that it has consistently blocked a global treaty that would make it easier for the blind and visually impaired to read books in formats like Braille. The thinking seems to be that it's more important to preserve copyright "inviolate" than to alleviate the suffering of hundreds of millions of people around the world.

You can read the disgusting details of how publishers have fought against the "proposed international instrument on limitations and exceptions for persons with print disabilities" for *30* years in an column I wrote back in 2011.

Amazingly, things have got even worse since then, with most of the fault lying at the feet of the US and EU, which are more concerned about placating their publishing industries than helping the poor and disabled around the world. And just when you think it can't get any worse, it does:

In a May 14, 2013 letter signed by Markus Beyrer, a Brussels based corporate lobby group known as Business Europe has sent a letter to Commissioners Michel Barnier and Karel De Gucht opposing the WIPO treaty on copyright exceptions for persons who are blind or have other disabilities. .... Business Europe describes itself as "the main horizontal business organization at the EU level." It represents 41 national business organizations in 35 European countries, claiming to promote "growth and competitiveness in Europe." Below is a list of the 55 member companies on its Corporate Advisory and Support Group, which describes its main constituency.

What readers of this blog may find most of interest are the names of the companies from the computer industry that are supporting this move to deny the blind even the smallest solace. Here are the main ones:

Facebook
IBM
Microsoft
Oracle

These are companies that often like to present themselves as decent and caring organizations whose pursuit of profit is balanced by a deep respect for fundamental human values. But their support here for the Business Europe lobbying group and its attempt to make it even harder for the blind to gain belatedly basic human rights like being able to read books – something that most of us are able to take for granted - is simply unacceptable.

I therefore call on Facebook, IBM, Microsoft and Oracle to dissociate themselves from the Business Europe group and its attempt to keep blind people in their darkness. If those companies refuse, we will know that their claims to any kind of humanity are shams, and should treat them with the contempt that they deserve.

13 May 2013

How Publishers Have Fought Against the Treaty for the Blind

One of the most disgraceful manifestations of the callousness of copyright maximalists is their 30-year refusal to countenance any meaningful kind of exception for blind users to convert texts into readable forms. Here's the background:

Even in 2013, blind people and others living with a print disability such as those with dyslexia still have very limited access to books. Only some 7% of published books are ever made accessible (in formats such as Braille, audio and large print) in the richest countries, and less than 1% in poorer ones. This is a “book famine”.

And here's what Fred Schroeder, First Vice President of the World Blind Union, said about the current state of the negotiations to change that:

The purpose of this treaty is to ensure access to books for blind people and help end the “book famine” we face. WBU is alarmed that some of the negotiators have focused their efforts almost exclusively on crafting language around copyright protections that have nothing to do with the ability of authorized entities to produce books for the blind and visually impaired. The shift away from a treaty for the blind to a treaty focussed on rights holder protections has taken up precious negotiating time which should be directed at ensuring a treaty that makes it possible for materials to be shared internationally.

I was naturally interested to find out what the UK's publishers had been doing on this front, so I put in a FOI request to the UK government:

I would be grateful if you could please supply me with the following information. 
Emails, letters and any other written communications from the last six months, between the Publishers Association or representatives of UK publishers, and the Intellectual Property Office, on the subject of the WIPO treaty for the blind (formally, the "Treaty to facilitate Access to Published Works by Visually Impaired Persons and Persons with Print Disabilities".)

You can find the full reply here; this is what KEI's Jamie Love wrote about the emails that were made available to me:

Overall, the emails deal extensively with publisher opposition to fair use (fair use is mentioned 40 times), and promotion of commercial availability and requests that the treaty include restrictive three-step test language (even while asserting that other treaties and agreements already mandate the three step test for all copyright exceptions). The emails also demonstrate the close cooperation and communication between the IPO and the publishers in the negotiations.

Although it's frustrating not to be able to see more, the emails provide a handy reminder just how much the UK government is willing to work with publishers to place obstacles in the way of the blind gaining access to even a fraction of the materials that sighted people are fortunate enough to access.

You would have thought that any caring human being would gladly support moves to alleviate the massive suffering this book famine causes to hundreds of millions of visually impaired people across the world, but apparently there are some who are immune to these feelings, because they regard preserving copyright's oppressive intellectual monopoly as far more important than helping the poor, the sick and the disadvantaged.

I find that desperately sad - and further proof of the harm that copyright inflicts on society as a whole, and particularly on the most vulnerable. 

03 May 2013

Please Help Save Open Source Seeds Now

Seeds have much in common with code.  Indeed, I wrote an entire book about how genomics parallels the world of software.  In particular, they suffer from the same problem: patents.  Patents give control over key technologies, which makes the corresponding commons even more valuable for the freedom it offers.

And alongside open source code, there are open source seeds.  These are those that have been developed over thousands of years by nameless farmers, and are owned by no one.  Anyone can sell them, or use them to develop new seeds.  They form part of humanity's greatest heritage.  And yet an ill-advised European regulation threats to consign open source seeds to the dustbin of history.

I've written a detailed explanation of what the issues are over on Techdirt.  Here I'd like to concentrate on what we can do about it.  Basically, we need to contact the European Commissioners before Monday, asking them not to take this step.  Here are their email addresses:

Viviane.Reding@ec.europa.eu, joaquin.almunia@ec.europa.eu, Siim.Kallas@ec.europa.eu, Neelie.Kroes@ec.europa.eu, Antonio.Tajani@ec.europa.eu, Maros.sefcovic@ec.europa.eu, Olli.Rehn@ec.europa.eu, Janez.Potocnik@ec.europa.eu, Andris.Piebalgs@ec.europa.eu, Michel.Barnier@ec.europa.eu, Androulla.Vassiliou@ec.europa.eu, Algirdas.semeta@ec.europa.eu, karel.de-gucht@ec.europa.eu, Maire.Geoghegan-Quinn@ec.europa.eu, Janusz.Lewandowski@ec.europa.eu, Maria.Damanaki@ec.europa.eu, Kristalina.Georgieva@ec.europa.eu, Johannes.Hahn@ec.europa.eu, Connie.Hedegaard@ec.europa.eu, stefan.Fule@ec.europa.eu, Laszlo.Andor@ec.europa.eu, Cecilia.Malmstrom@ec.europa.eu, Dacian.Ciolos@ec.europa.eu, Tonio.Borg@ec.europa.eu

I'm sorry for the extremely short notice, but I found out about this just a few weeks ago, and have been trying to get my head around what is really going on.  Basically, this would give control of Europe's food supply to the multinational giants like Monsanto, and ensure that our food is increasingly "owned" through the presence of patents.  That's insane for the reasons that I note below.

Here's what I've sent off:


I am writing to you to urge you to object to the regulation of the licensing and sale of seeds, which I believe you will consider next week. 
Although I appreciate that the impulse behind this was laudable enough – to ensure that plant material that is available in the EU is safe, and that problems can be tracked back to their source – the way it is being implemented seems fraught with problems. 
First, there is the huge bureaucratic burden that is being imposed upon seed suppliers. These will fall especially hard on small and medium-sized enterprises, a group that I know you are keen to promote.

Perhaps even worse, it will mean that thousands of ancient varieties that are unencumbered and in the public domain will never be registered or certified, and thus will fall out of use. That is a terrible loss of thousands of years of European culture – civilisation was built on seeds, which made cities and all that they bring possible.
 
That will result in a loss of diversity at a time when European agriculture is facing unprecedented challenges thanks to climate change. The seed licensing proposals make it likely that fewer, less varied seeds will be used; this will make food supply in Europe far less resilient, and more vulnerable to diseases. It will also make European farmers dependent on a small group of large seed suppliers who will be able to exercise oligopoly power with all that this implies for pricing and control. 
Finally, these changes will result in tens of millions of ordinary citizens across Europe – the ones who delight in the simple pleasures of gardening – finding themselves limited in the seeds that they can buy and sow. At the very least this is likely to lead to an increasing disillusionment with the European project, something that we all would wish to avoid at a time when many are expressing their doubts on this score. 
In summary, I ask you to reject the regulation in its current form, and to insist that it be modified to allow Europe ancient seed heritage to be preserved and enjoyed by future generations, and to ensure that European agriculture remains strong and independent.   

 Please help if you can: this is important.