Friday, February 22, 2013

Competition and IP Issues in Film Industry in India



FICCI Multiplex Association filed information to CCI, claiming that film producers and distributors under the umbrella of United Producers and Distributors forum are refusing to deal with multiplexes to release their film. Multiplex can show only feature films in their theaters. So an essential input is denied to multiplexes. It is anti-competitive under Section 3 of Competition Act 2002 (hereinafter Competition Act). Director General under Competition Act investigated in the matter and found that prima facie there is possibility of an anti-competitive activity.
Further UPDF member argued that they have not formed cartel. Multiplex owners have formed a cartel and there was an anti-competitive activity under Monopolistic and Restrictive Trade Practices Act. It was held restrictive trade practice by Monopolistic and Restrictive Trade Practices Commission. They further argued that UPDF is efficiency increasing joint venture. Joint venture in form of horizontal agreement is exempted from being anti-competitive if they are increasing efficiency.[1]     
 During this case sub judice before CCI, UPDF filed a case in Bombay High Court alleging that CCI does not have jurisdiction in matters involving film, which is subject matter of copyright. The case is in name of Amir Khan Pvt. Limited v. Competition Commission of India.[2] Copyright owner has the right to release the work to public or not do so under Copyright Act 1957. If there is any concern of interested parties regarding copyrighted material. The obvious remedy under Copyright Act 1957 is compulsory licensing of copyrighted material. The petitioner argued that CCI does not have any jurisdiction to deal with issues involving Copyright. It further alleged that CCI has formed an opinion through Director General Report that there is anti-competitive activity. Honorable Bombay High Court held that CCI has power to decide jurisdictional issues except the question relating to its own establishment under Competition Act. Investigation by Director General is not formation of opinion. The remedy available under Competition Act is in addition to other laws and not in derogation.[3] Competition Act has overriding power over other legislations.[4] 
C. Issues
1.      Whether UPDF is a Cartel or not?
2.      Whether feature film has blanket exemption under Section 3(5)(i) of Competition Act 2002 from being anti-competitive agreement?
D. Order
Cartel is a horizontal activity.[5] Competition Act 2002 provides inclusive definition of cartel. So there is legislative intent to make definition of cartel broader. “"cartel" includes an association of producers, sellers, distributors, traders or service providers who, by agreement amongst themselves, limit, control or attempt to control the production, distribution, sale or price of, or, trade in goods or provision of services”[6] Use of word or before service providers indicate that it includes horizontal agreements only.
In present case UPDF is an association of producers and distributors. Producers and distributors are market players at different level of business. Producers are involved in making of film. On the other hand distributors only distribute films to multiplexes and single screen theatre. However there is trend of integration of production and distribution in Indian film industry to some extent. Whether this vertical integration of film industry makes UPDF a horizontal arrangement is a question to be analysed.
CCI in its order said that UPDF is involved in Cartel like activity under Section 3(3) of Competition Act. Horizontal agreements are dealt under Section 3(3) of Competition Act.[7] It is to be noted that UPDF has both producers and distributors as its members. CCI in its order describes at many places that this is a vertical arrangement.
CCI stated that there is no explanation is given on reasonableness under Section 3(5)(i) and there is no judicial precedent on this concept. In order to interpret Section 3(5) CCI pointed out two factor test to analyse whether it falls under exemption or not. First, whether the activity is to restrain infringement. Second, whether the activity in question is reasonable conditions imposed under IP laws. Infringement of IPRs depends upon the specific rights under IP laws. So CCI discussed the rights under Copyright Act 1957 in detail.
For cinematographic films there is right make copies, to sell or give on hire, to communicate the film to public. Copyright is subject to other provisions of Copyright Act and other laws as well.[8] Other laws may include Competition Act also. Thus cumulative reading of all these provisions makes it clear that copyright is a statutory right subject to the provisions of the Copyright Act, 1957. It is not an absolute right.  There is no right which the copyright Act does not expressly create. It cannot be inferred or claimed under the said Act.[9] The legislative intent of Copyright Act was to grant a higher protection to pure original artistic works such as paintings, sculptures etc. and lesser protection to design activity which is commercial in nature. The legislative intent is, thus, clear that the protection accorded to a work which is commercial in nature is lesser than and not to be equated with the protection granted to a work of pure Art.[10]

CCI stated that multiplexes do not want to infringe the Copyright of films of UPDF members. They want to get license which is essential and sole input of their business. So there is no question restraining the infringement by restricting the supply of feature film in the present case. Regarding the reasonable use of IPRs CCI said that there is no question of exercise of Copyright under the present case. So exemption under Section 3(5)(i) is not available under this case.

Regarding efficiency increasing Joint Venture CCI said that UPDF has not provided any data relating to increase in efficiency in this case. CCI said Joint Ventures do not have blanket exemption under proviso to Section 3(3) of Competition Act 2002. In case of efficiency increasing Joint Venture it gets exemption from per se rule. Generally horizontal agreements are per se anti-competitive. However, in case of efficiency increasing Joint Venture the rule of reason approach will apply.
CCI considered the six factors under Section 19(3) of Competition Act 2002 which are necessary to determine anti-competitiveness of a business activity. First three factors are related to entry barriers. CCI held that there were potential entry barrier existed. Last three factors are related to scientific development, consumer interest and improvement in production which were not present in this case.
CCI referred to US and European jurisdiction cases. CCI referred to four foreign cases on the similar issues. Citing United States v. Microsoft[11] CCI said that copyright does not provide immunity from general law including anti-trust law. Similar stand was taken by CCI in this case. Otter Tail Power Co. v. United States[12], the court held that essential facilities should be provided at non discriminatory basis. Here in this case feature films are essential facility to multiplexes.
In the present case there was no issue of emerging of new product in market. But CCI cited ECJ decision in Maggil (Radio Telefilms Eireann) (RTE) and Independent Television Publication Limited ruled that refusal in this case amounted to preventing a new product in market which had a potential consumer demand. Twentieth century Music Corp. v. Aiken US 151, 156 (1975), the objective of our copyright law is to provide fair return for creative labour.   
CCI held that it is an anti-competitive activity. UPDF was refrained from indulging in anti-competitive activity and penalty of one lakh each was imposed on 27 UPDF members.[13]  

E. Analysis
If an act or practice of intellectual property owner is to avoid infringement or IPRs owner is exercising right specifically provided under IP laws. It will be exempted under Section 3(5)(i) of Competition Act 2002. Otherwise there is no exemption to IPRs. Exemption provision in its present form does not provide clearly about relation between competition law and IPRs. If this provision would not be there CCI could pass the similar order in this case. CCI rightly pointed the need to include explanation to reasonableness under Section 3(5)(i). Not only explanation to provision but there is need of comprehensive guidelines to deal with patent pooling, standard setting, grant back, cross licensing etc.  


[1] Proviso to Section 3(3) of Competition Act 2002.
[2](112)BomLR3778, 2010CompLR105, [2010]102SCL457(Bom).
[3] Section 62 of Competition Act 2002.
[4] Section 60 of Competition Act 2002.
[5] See T. Ramappa, Competition Law in India Policy Issues and Developments, Oxford India Paperbacks p. 86.
[6] Section 2(c) of Competition Act 2002.
[7] Section 3(3): “Any agreement entered into between enterprises or associations of enterprises or persons or associations of persons or between any person and enterprise or practice carried on, or decision taken by, any association of enterprises or association of persons, including cartels, engaged in identical or similar trade of
goods or provision of services, which—
(a)  directly or indirectly determines purchase or sale prices;
(b)  limits or controls production, supply, markets, technical development,
investment or provision of services;
(c)  shares the market or source of production or provision of services by way of allocation of geographical area of market, or type of goods or services, or number of customers in the market or any other similar way;
(d)  directly or indirectly results in bid rigging or collusive bidding, shall be presumed to have an appreciable adverse effect on competition: Provided that nothing contained in this sub-section shall apply to any agreement entered into by way of joint ventures if such agreement increases efficiency in production, supply, distribution, storage, acquisition or control of goods or provision of services....”
[8] Section 16 of Copyright Act 1957.
[9] The Gramophone Company of India Ltd. v. Super Cassette Industries Ltd. (Decided on 01.07.2010) MANU/DE/1801/2010.
[10] Microfibres Inc. v. Girdhar and Co. RFA (OS) No. 25/2006 (DB), decided on 28.05.2009.
[11] [38 1998 WL 614485].
[12] 410 US 366 (1973).
[13] Ten lakh is equal to one million.


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