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Legal Framework for Collective Management in Nigeria

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Abstract

Every civilized society is made up of a system of rules, norms, and laws that govern the activities of those living within it. The absence of such a system whether written or unwritten always results in anarchy with everyone taking matters into his/her hands and in the words of Eric Engle “leads straight to the law of the jungle with no exit”.

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Notes

  1. 1.

    Engle 2008 35 N. Ky. L. Rev 1. Aristotle noted, that it is precisely the fact that humans live in States that marks human society and separates it from other social and specialized animals such as bees or wolves. Other animals are social. But human society is the most complex. Poetically, Aristotle notes that he who lives outside the state is either a brute beast or a god. Because humans are rational, political (social) animals with the gift of speech we live in cities and not as savages. Thus, our laws are higher than those of a dagger wielding thief.

  2. 2.

    The Holy Bible, King James Version Judges 21:25. “In those days there was no king in Israel: every man did that which was right in his own eyes”.

  3. 3.

    Supra at footnote 1.

  4. 4.

    See Carrol Intellectual property rights 15 where he addressed the “what” of a legal framework intertwining it with his heading by noting that “Intellectual property rights have been tailored before and will be tailored again”. He further notes that “it is time to have a framework for analyzing this activity and to recognize its potential value in rendering intellectual property rights better suited to their task(s)”.

  5. 5.

    See Dinwoodie One size fits all 12 where he opined on “why” the Berne and Paris conventions were made noting that they were aimed at developing an international system designed to constrain rampant piracy and slowly expand core forms of protection.

  6. 6.

    See Carrol Op cit (footnote 4) where he opines on “when and why” Intellectual property rights are granted. Answering from an economic point of view he notes that it stimulates investments in innovation and cultural productions.

  7. 7.

    Ibid. In respect of the “how” Carrol noted that TRIPS followed the structural framework of minimum norms established by Berne and Paris. In his conclusion at page 14 he reasons that “clearly one size does not fit all” whether of a single Intellectual property regime or while still eradicating differences and applications of the rules within a single regime.

  8. 8.

    See Litman Copyright Non-Compliance 427 where she discussed the dilemma of the user publics who generally do not believe that the laws that exist actually exist. She noted that “the trouble with the plan is that the only people who appear to actually believe that the current copyright rules apply as writ to every person on the planet are the member of the copyright bar… but that’s a far cry from persuading the ten or twenty million new printers and reprinters”.

  9. 9.

    Ibid, Litman opined that “people don’t obey laws that they don’t believe in…Most people try to comply, at least substantially, with what they believe the law to say. If they don’t believe the law says what it in fact says, though, they won’t obey it-not because they are protesting its provisions, but because it doesn’t stick in their heads”.

  10. 10.

    Gervais Collective Management 12 Available online at http://aix1.uottawa.ca/~dgervais/publications/collective_management.pdf.

  11. 11.

    See the report Commissioned by the Copyright Licensing Agency and prepared by PricewaterhouseCoopers LLP (PwC) “An economic analysis of copyright, secondary copyright, and collective licensing”. Available online at http://www.ipo.gov.uk/ipreview-c4e-sub-plsreport.pdf Date of use: 24 March 2012 at 37.

  12. 12.

    Gervais Op cit footnote 10 where he identified the 4 main classifications under the Canadian Copyright law as follows:

    1. 1.

      Music performing and certain neighboring rights (Section 67 of the Copyright Act);

    2. 2.

      General regime (Section 70);

    3. 3.

      Particular cases” regime (retransmission and educational institutions Section 71); and

    4. 4.

      Private copying.

    .

  13. 13.

    Ibid. The Copyright Board listed existing Canadian collectives and identified the following areas:

    1. 1.

      Music

    2. 2.

      Literary

    3. 3.

      Audiovisual and multimedia

    4. 4.

      Visual arts

    5. 5.

      Retransmission

    6. 6.

      Private copying

    7. 7.

      Educational rights

    8. 8.

      Media monitoring

    .

  14. 14.

    Ibid. Rights may be acquired voluntarily, non-voluntarily or by some other mechanism.

  15. 15.

    See S.39 (2)a of the Nigerian Copyright Act which provides that collecting societies must be registered as companies limited by guarantee and under the Companies and Allied Matters Act of 2004. A company limited by guarantee is a not-for-profit company.

  16. 16.

    PwC report Op Cit at footnote 11.

  17. 17.

    Ibid. It is noteworthy that the PWC report focused on literary and artistic works (i.e., books, journals, magazines and other periodicals, paintings, sculptures and other artistic works).

  18. 18.

    See Introduction To Collective Management Of Copyright And Related Rights available online at http://uatm.com.ua/laws/int/Introduction%20to%20Collective%20Management%20of%20Copyright%20and%20Related%20Rights.pdf Date of use: 24 March 2012 where the core mandates of a collective management organization were highlighted as follows:- “In the framework of a collective management system, owners of rights authorize collective management organizations to administer their rights, that is, to monitor the use of the works concerned, negotiate with prospective users, give them licenses against appropriate fees and, under appropriate conditions, collect such fees and distribute them among the owners of rights”.

  19. 19.

    See for example Section 39(8) of the Nigerian Copyright Act which provides that “collecting society means an association of copyright owners which has as its principal objectives the negotiating and granting of licenses, collecting and distributing of royalties in respect of copyright works; group of persons includes a body corporate”.

  20. 20.

    Uchtenhagen The Setting up of New Copyright Societies 17.

  21. 21.

    Ibid. Ulrich suggested that only those authors and publishers with accounts exceeding a certain minimum should be granted voting rights.

  22. 22.

    Ibid.

  23. 23.

    This Act was originally promulgated as Copyright Decree (No 61) of 1970 and later re-designated as the Copyright Act by the operation of the Adaptation of Laws (Re-designation of Decrees) Order No.13 of 1980. It repealed the 1911 Copyright Act of the United Kingdom which had been extended to Nigeria in 1912.

  24. 24.

    The interpretation section of the Act ( Nigeria Copyright Act 1970) defined Commissioner as the Commissioner for Trade.

  25. 25.

    Section 13(1) of the Nigerian Copyright Act 1970.

  26. 26.

    Section 13(2) provided an interpretation for licensing body. “In this subsession “licensing body” means a society, firm or other Organization which has its main object, or one of its main objects, the negotiation or granting of licences in respect of copyright works, and includes an individual carrying on the same activity.

  27. 27.

    See Section 13(2) of the Nigerian Copyright Act 1970 which provided that where a licensing body unreasonably refuses to grant licences or is imposing unreasonable terms for the grant of licences, the competent authority may direct in relation to a work covered under the licensing bodies purview that a licence shall be deemed to have been granted by the licensing body upon payment of the prescribed fees.

  28. 28.

    Section 13(3) of the Nigerian Copyright Act 1970.

  29. 29.

    The section provides that the outcome of such appeal shall be final.

  30. 30.

    Section 15(5) placed the powers to make regulations on the Commissioner. It listed five issues that could be covered by the regulation as follows: The Commissioner may make regulations-

    1. 1.

      prescribing how matters may be referred to the competent authority,

    2. 2.

      prescribing the procedure, records to be kept and member of the competent authority who shall preside at its sittings,

    3. 3.

      prescribing the manner in which the competent authority shall be convened and the place where it shall hold its sittings,

    4. 4.

      prescribing a scale of costs and fees, and

    5. 5.

      providing generally for the better carrying out of the functions assigned to the competent authority by this Decree.

  31. 31.

    See Section 13(2) of the Nigerian Copyright Act 1970 where the responsibility of licensing bodies was indicated as being to negotiate and grant licences. The Act does not place any conditions or restrictions to the exercise of that power.

  32. 32.

    Ibid. The subsection provided that where the licensing body unreasonably refused to grant a licence, the competent authority could direct that the licence sought be deemed to have been granted.

  33. 33.

    Op cit footnote 11.

  34. 34.

    Asein Nigerian Copyright Law 219.

  35. 35.

    Ibid.

  36. 36.

    Okoroji Copyright, Neighbouring Rights & the New Millionaires 167.

  37. 37.

    Ibid.

  38. 38.

    Ibid at 195 where it was said that “one of the important contents of the Draft Copyright Law submitted to the government jointly by the Nigerian Law Reform Commission and the Drafting Committee of the National Seminar on the Nigerian Copyright Law, was a provision in Section 35 for the regulation of collective administration of copyright in Nigeria”.

  39. 39.

    See Ibid at 196 where Okoroji who was a member of the Draft Copyright Law Committee expressed surprise at the deletion of the provision purportedly drafted to regulate copyright collective administration and further noted at page 195 that MCSN’s “obvious objective was to abort any attempt to regulate collective administration of copyright”.

  40. 40.

    Copyright Amendment Decree No.98 of 1992. See also Okoroji Copyright, Neighbouring Rights & the New Millionaires 167.

  41. 41.

    See Okoroji Copyright, Neighbouring Rights & the New Millionaires 199 where he said; “Except for minor changes, the new Section 32B was in fact the same section 35 deleted from the original draft of the law”.

  42. 42.

    The 1998 Act as Amended in 1992 and subsequently 1999 is now known as the Nigerian Copyright Act, Chapter C28, Laws of the federation of Nigeria 2004. The 2004 laws were re-arranged, thus Section 32B of the old Act is now the current Section 39 of the Nigerian Copyright Act 2004.

  43. 43.

    Section 39 is titled Collecting Society.

  44. 44.

    Section 39(1) provides for formation of a collecting society and application for approval.

  45. 45.

    Section 39(2)a–d provides the conditions for approving a collecting society.

  46. 46.

    Section 39(2)a addresses the for-profit or not-for-profit nature of a collecting society in Nigeria.

  47. 47.

    Section 392) and (8) are similar provisions highlighting the general duties/principal objectives of a collecting society.

  48. 48.

    Section 39(1 and 3) addresses the issue of single or multiple collecting societies in Nigeria.

  49. 49.

    Section 39(4), (5) and (6) the combined reading of these subsections criminalizes the act of performing the activities of a collecting society without the approval of the Commission.

  50. 50.

    Section 39(7).

  51. 51.

    See Gervais, Collective Management 26 where he identified six aspects of collective administration of rights as it relates to legal and regulatory frameworks. The six identified aspects are: (1) The legal Status of CMO’s; (2) The mode of rights acquisition; (3) Legislative support, if any; (4) State Control of CMO’s (formation and/or operation; (5) Tariff and licensing practices and (6) distribution practices and accounting).

  52. 52.

    Section 32B of the 1988 Act is now Section 39 of the current Act (2004).

  53. 53.

    This terminology is one and the same with Collective Management Organization as the Copyright (Collective Management Organization) Regulation 2007 uses that nomenclature.

  54. 54.

    The definition of a collecting society provided at Section 39(8) provides that it means an “association of copyright owners”.

  55. 55.

    See Section 39, 39(1) and Section 39(8).

  56. 56.

    The amendment to the Act in 1999 specified “50” as the minimum number of persons a collecting society is expected to represent to entitle such a society to initiate or commence infringement actions. See Section 17 of the Nigerian Copyright Act 2004. This section was Section 15A under the old Act. At Reg 1(2)e of the CMO Regulation, a membership list of not less than 100 right owners is required from any company applying for licence to operate as a CMO.

  57. 57.

    See Section 26(1) of the Companies and Allied Matters Act 1990 (hereinafter referred to as CAMA) which provides that a company limited by guarantee is one formed for the purposes of promoting commerce, art, science, religion, sports, culture, education, research, charity or other similar objects and the income and property are to be applied solely toward the promotion of its objects and no portion thereof is to be paid or transferred directly or indirectly to the members of the company except as permitted by this decree.

  58. 58.

    See Section 26(4) CAMA which states that “a company limited by guarantee shall not be incorporated with the object of carrying on business for the purposes of making profits for distribution to members”. Interestingly, one of the principal objectives of a collecting society is the distribution of royalties to copyright owners. A line of difference can be drawn between the distribution of profit and royalty, hence collecting societies are registered as companies limited by guarantee under CAMA.

  59. 59.

    See Gervais Collective Management 26.

  60. 60.

    Ibid.

  61. 61.

    See Introduction To Collective Management Of Copyright And Related Rights available online at http://uatm.com.ua/laws/int/Introduction%20to%20Collective%20Management%20of%20Copyright%20and%20Related%20Rights.pdf Date of use: 26 March 2012”.

  62. 62.

    Ibid at paragraph 21 page 5.

  63. 63.

    Section 39(4) Nigerian Copyright Act.

  64. 64.

    Section 39(5) Nigerian Copyright Act.

  65. 65.

    Section 39(6) Nigerian Copyright Act.

  66. 66.

    See Section 39 (7) Nigerian Copyright Act.

  67. 67.

    Ibid.

  68. 68.

    Shyllon Intellectual Property Law in Nigeria 130.

  69. 69.

    The Copyright (Collective Management Organization) Regulations 2007 at Regulation 21 revoked the copyright (Collecting Societies) Regulation 1993.

  70. 70.

    Regulation 4, Copyright (Collecting Societies) Regulation, 1993.

  71. 71.

    Regulation 6, Copyright (Collecting Societies) Regulation, 1993.

  72. 72.

    Regulations 11, 12, and 13, Copyright (Collecting Societies) Regulation, 1993.

  73. 73.

    Regulation 15, Copyright (Collecting Societies) Regulation, 1993.

  74. 74.

    Regulation 16, Copyright (Collecting Societies) Regulation, 1993.

  75. 75.

    Regulation 17, Copyright (Collecting Societies) Regulation, 1993.

  76. 76.

    Regulation 4 (1) Copyright (Collecting Societies) Regulation, 1993.

  77. 77.

    Ibid.

  78. 78.

    See Regulation 4 (2), Copyright (Collecting Societies) Regulation, 1993 which provides that the authorized agent must be a legal practitioner.

  79. 79.

    Regulation 4 (3), Copyright (Collecting Societies) Regulation, 1993.

  80. 80.

    Regulation 4 (3)a Copyright (Collecting Societies) Regulation, 1993. The certificate of incorporation of a company is prima facie evidence that the company has been registered. See Section 36(6) CAMA. Certificates of registration are issued by the Corporate Affairs Commission, the agency established by CAMA.

  81. 81.

    Regulation 4 (3)b, Copyright (Collecting Societies) Regulation, 1993. The memorandum of association is expected among other things to contain the object of business of a company, in the case of a collecting society, its proposed principal aims and objectives. See Section 27(1)c.

  82. 82.

    Regulation 4 (3)c, Copyright (Collecting Societies) Regulation, 1993. The registration of the memorandum and articles of association has the effect of a contract under seal. See Section 41(1) CAMA.

  83. 83.

    Regulation 4 (3)d, Copyright (Collecting Societies) Regulation, 1993.

  84. 84.

    Regulation 6(1)a, Copyright (Collecting Societies) Regulation, 1993.

  85. 85.

    Regulation 6 (1)b, Copyright (Collecting Societies) Regulation, 1993.

  86. 86.

    Regulation 6 (1)c, Copyright (Collecting Societies) Regulation, 1993.

  87. 87.

    In 1995, the Nigerian Copyright Council was changed to Nigerian Copyright Commission.

  88. 88.

    Regulation 6 (1)d, Copyright (Collecting Societies) Regulation, 1993.

  89. 89.

    Regulation 6 (1)e, Copyright (Collecting Societies) Regulation, 1993.

  90. 90.

    Regulation 6 (1)f, Copyright (Collecting Societies) Regulation, 1993.

  91. 91.

    Regulation 7 (2), Copyright (Collecting Societies) Regulation, 1993.

  92. 92.

    Section 39 (3) Nigerian Copyright Act states “The commission shall not approve another society in respect of any class of copyright owners, it is satisfied that an existing approved society adequately protects the interest of that class of copyright owners.

  93. 93.

    In this regard it may be useful to consider what was said earlier at Para 3.3.3.6 above.

  94. 94.

    Regulation 9, Copyright (Collecting Societies) Regulation, 1993.

  95. 95.

    Regulation 10, Copyright (Collecting Societies) Regulation, 1993.

  96. 96.

    Regulation 16, Copyright (Collecting Societies) Regulation, 1993.

  97. 97.

    Regulation 17, Copyright (Collecting Societies) Regulation, 1993.

  98. 98.

    Regulation 11, Copyright (Collecting Societies) Regulation, 1993.

  99. 99.

    Regulation 12 (1), Copyright (Collecting Societies) Regulation, 1993.

  100. 100.

    Regulation 12 (2), Copyright (Collecting Societies) Regulation, 1993.

  101. 101.

    Regulation 15 (1), Copyright (Collecting Societies) Regulation, 1993.

  102. 102.

    Ibid.

  103. 103.

    Regulation 15 (2), Copyright (Collecting Societies) Regulation, 1993.

  104. 104.

    Ibid.

  105. 105.

    Regulation 15 (4), Copyright (Collecting Societies) Regulation, 1993.

  106. 106.

    Regulation 15 (5), Copyright (Collecting Societies) Regulation, 1993.

  107. 107.

    Copyright Amendment Decree No.42 1999.

  108. 108.

    Section 15A. The provision in the current Act is now Section 17.

  109. 109.

    (1996) F.H.C.L.R 473.

  110. 110.

    This provision is now Section 16 under the current law.

  111. 111.

    On this matter see also the similar judgment of Jinadu J in MCSN v Nigeria Hotels Suit No FHC/L/43/89.

  112. 112.

    Okoroji Copyright Neighbouring Rights and The New Millionaires 180.

  113. 113.

    See Adewopo, Nigerian Copyright System: Principles and Perspectives 106 where he noted that “the above development culminated in a zero collective administration state in the music industry, which situation has foisted a situation of complete helplessness on the innocent right owners and artistes in the music industry.” See also Okoroji Copyright Neighbouring Rights and The New Millionaires 182.

  114. 114.

    The meeting was held at the Topview Hotel, Abuja. The resolution was made on the last day of the meeting, on May 22, 2007.

  115. 115.

    Chief Bayo Ojo was the Honorable Attorney General of the Federation and Minister for Justice at the time.

  116. 116.

    See Generally Adewopo, Nigerian Copyright System: Principles and Perspectives 106 and Okoroji Copyright Neighbouring Rights and The New Millionaires 182.

  117. 117.

    Adewopo, Nigerian Copyright System: Principles and Perspectives 106 and (Okoroji Op Cit at 241).

  118. 118.

    Ibid.

  119. 119.

    on the 28th of September, 2007.

  120. 120.

    as No.98 of volume 94, on the 3rd of October, 2007.

  121. 121.

    See Regulation 22 where Collective Management Organization was interpreted to mean Collecting Society.

  122. 122.

    Regulation 1 Copyright (Collective Management Organizations) Regulations 2007 (hereinafter referred to as CMO Reg).

  123. 123.

    The prescribed form is attached to the regulation as a schedule and tagged FORM NCC/CSR 1.

  124. 124.

    See Regulation 18 CMO Reg.

  125. 125.

    See Regulation 1 CMO Reg.

  126. 126.

    See Regulation 6 (1)a–f Copyright (Collecting Societies Regulation) 1993 which provided that the subscribers to the memorandum of association shall not be less than 10 persons with proven interests in the areas which the company desires to operate as a collecting society. The organs of the company to comprise a General Assembly and a management Board; the Chief Executive Officer of the company must not be a member of the society; the Management Board of the company shall include one member of the Commission; the Chairman of the Management Board must be a member of the society; evidence of adequate and competent staff.

  127. 127.

    Regulation 1 (3)a CMO Reg.

  128. 128.

    Regulation 1(3)b CMO Reg.

  129. 129.

    Regulation 1 (3)c CMO Reg.

  130. 130.

    Regulation 1 (3)d CMO Reg.

  131. 131.

    Regulation 1 (3)e CMO Reg.

  132. 132.

    Regulation 1(3)f CMO Reg.

  133. 133.

    Regulation 1 (3)g CMO Reg.

  134. 134.

    Regulation 1 (3)h CMO Reg.

  135. 135.

    See Regulation 2 (d) CMO Reg.

  136. 136.

    See Regulation 2 (e) CMO Reg.

  137. 137.

    See Regulation 2 (f) CMO Reg.

  138. 138.

    See Regulation 2 (g) CMO Reg.

  139. 139.

    See Regulation 1 (3)c CMO Reg.

  140. 140.

    See Regulation 1 (3)d CMO Reg.

  141. 141.

    See Regulation 1 (5) CMO Reg.

  142. 142.

    See Regulation 1 (6) CMO Reg.

  143. 143.

    See Regulation 1(8) CMO Reg.

  144. 144.

    See Regulation 1 (9) CMO Reg.

  145. 145.

    See Regulation 3 (1) CMO Reg.

  146. 146.

    See Regulation 3 (2&3) CMO Reg which provides that “The Commission may, refuse to approve an application for renewal of a licence if, it is of the opinion that the CMO no longer meets the requirement for grant of licence”.

  147. 147.

    See Regulation 2 CMO Reg.

  148. 148.

    See Regulation 5 (1) CMO Reg.

  149. 149.

    See Regulation 4 (1) CMO Reg.

  150. 150.

    See Regulation 4 (2) CMO Reg.

  151. 151.

    See Regulation 4(5) CMO Reg.

  152. 152.

    See Regulation 7 (1) CMO Reg.

  153. 153.

    See Regulation 9 (1) CMO Reg.

  154. 154.

    See Regulation 7 (2) CMO Reg.

  155. 155.

    See Regulation 8 CMO Reg.

  156. 156.

    See Regulation 11 CMO Reg.

  157. 157.

    See Regulation 12 (1) CMO Reg which provides a maximum period of 7 years as the holding period.

  158. 158.

    See Regulation 12 (2) CMO Reg.

  159. 159.

    See Regulation 10 CMO Reg.

  160. 160.

    See Regulation 13 (1) CMO Reg.

  161. 161.

    See Regulation 13 (3) CMO Reg where issues to be taken into consideration are enumerated.

  162. 162.

    See Regulation 13 (2) CMO Reg.

  163. 163.

    Regulation 13 (3)a–g.

  164. 164.

    Regulation 13( 4).

  165. 165.

    See Regulation 14 CMO Reg.

  166. 166.

    Issued on the 2nd October 2007, Government Notice No.66 Vol 94 P B429-438.

  167. 167.

    See Regulation 15 CMO Reg.

  168. 168.

    See Regulation 17 CMO Reg.

  169. 169.

    See Regulation 18 CMO Reg.

  170. 170.

    See Regulation 16 CMO Reg.

  171. 171.

    Regulation 17 (1)a CMO Reg.

  172. 172.

    Regulation 17 (1)b CMO Reg.

  173. 173.

    Regulation 17 (1)c CMO Reg.

  174. 174.

    See Regulation 17 (1)d CMO Reg where it was noted that “discriminating in the provision of licence to members of the same user class, either in the terms of such licence, or differential tariff rate, except such differential treatment can be reasonably justified, based on peculiar facts and circumstances applicable to the said user class”.

  175. 175.

    Regulation 17 (1)e CMO Reg.

  176. 176.

    See Regulation 17 (1)f CMO Reg where it was noted that such information may include but is not limited to:

    1. 1.

      information regarding the repertoire of an author who has assigned works to both Collective Management Organization;

    2. 2.

      information held by a Collective Management Organization that may assist the requesting Collective Management in the computation and equitable distribution of royalties; and

    3. 3.

      information on the existing reciprocal representation agreement if any of a Collective Management Organization.

  177. 177.

    Regulation 17 (1)g CMO Reg.

  178. 178.

    Regulation 17 (1)h CMO Reg.

  179. 179.

    Regulation 1 (2)d CMO Reg.

  180. 180.

    Regulation 1 (2)e CMO Reg.

  181. 181.

    Regulation 1 (2)f CMO Reg.

  182. 182.

    Regulation 1(2)g CMO Reg.

  183. 183.

    Regulation 1 (3)c CMO Reg. It should be noted that neither the Nigerian Copyright Act nor the Regulations (Old or New) provides the yardstick for determining competence. The provisions within this particular subsection that the CEO be knowledgeable in copyright matters may provide some guidance as to competence. Following this provision, the standard for judging competence may be assessed against the level of copyright knowledge possessed by the aspiring CEOs.

  184. 184.

    Regulation 1 (3)d CMO Reg. This particular regulation provides no guide as to the determination of competence. Reference may however be made to Regulation 1(3)c for guidance.

  185. 185.

    Regulation 1 (3)f CMO Reg.

  186. 186.

    Regulation 2 CMO Reg.

  187. 187.

    Regulation 1(4) CMO Reg.

  188. 188.

    Regulation 1 (9) and Regulation 3 CMO Reg.

  189. 189.

    Regulation 7 (1) CMO Reg.

  190. 190.

    Regulation 7 (2)a CMO Reg.

  191. 191.

    Regulation 7 (2)b CMO Reg.

  192. 192.

    Regulation 10 CMO Reg.

  193. 193.

    Regulation 13 (5) CMO Reg.

  194. 194.

    Regulation 14 CMO Reg.

  195. 195.

    Regulation 14 CMO Reg and Copyright (Dispute Resolution Panel) Rules 2007.

  196. 196.

    Regulation 19 CMO Reg.

  197. 197.

    Regulation 18 CMO Reg.

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Ola, O. (2013). Legal Framework for Collective Management in Nigeria. In: Copyright Collective Administration in Nigeria. SpringerBriefs in Law. Springer, Berlin, Heidelberg. https://doi.org/10.1007/978-3-642-35819-7_3

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