PTC FORUM : PUBLICATIONS
CHINA / COPYRIGHT / HYPERLINKS
Internet Service Providers' liability for hyperlinks
Wang Fanwu
China Patents and Trademarks, Vol 15 No 2, April 2001
This article, by the Deputy Presiding Judge, Intellectual Property Tribunal,
Beijing No 2 Intermediate People's Court, is based on a recent case, raising
issues of interest to Internet users and providers throughout the world. In
Liu Jinsheng v Sohu Aitexin Infor-Tech (Beijing) Co Ltd, the plaintiff alleged
that the defendant's website had infringed his copyright by publishing without
authorization his translation of Don Quixote, enabling Internet users to browse
and download it. The defendant, an Internet Service Provider, denied uploading
the work but said that it had legitimate hyperlinks to three websites on which
the translation was available. It appears that these websites were not authorised
to display the translation. The Court held that, having failed (at first) to
comply with the plaintiff's request to discontinue the hyperlinks, the defendant
had infringed copyright law. The author of the article points out that hyperlinking
is merely a tool for searching other websites and is neither an act of reproduction
nor a form of dissemination of a copyright work. If the hyperlinked information
is "flawed", as the author puts it, it is for the transmitters of
the information rather than the Internet Service Providers to be legally responsible.
However, in the present case, the plaintiff had drawn the defendant's attention
to the "flaw"; and the defendant, instead of taking active measures
to discontinue the hyperlinks with the websites on which the plaintiff's work
was illegally uploaded, maintained the hyperlink. He thereby encouraged the
infringement. "Although it is hard for a defendant to manage the information
content on the websites with which it is hyperlinked, it is technically possible
to control the hyperlink between the [defendant's] website and other websites."
By failing to exercise this control, after being told that the plaintiff's copyright
had been infringed, the defendant rightly incurred a legal liability for extending
the infringement. [20055]