Most notably we regret that the Directive does not strike the right balance between the protection of right holders and the interests of EU citizens and companies. It therefore risks to hinder innovation rather than promote it and to have a negative impact the competitiveness of the European Digital Single Market.
Furthermore, we feel that the Directive lacks legal clarity, will lead to legal uncertainty for many
stakeholders concerned and may encroach upon EU citizens’ rights.

We therefore cannot express our consent with the proposed text of the Directive.