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The European Bureau of Library, Information and Documentation Associations is an independent umbrella association of library, information and documentation associations and institutions in Europe.

The European Parliament must improve the TDM exception

26 March 2018


We, members of 28 organisations representing universities, large and small technology companies, telecommunications and Internet services providers, startups and scaleups, libraries, scientific and research funding and performing organisations, open access publishers, investigative and data journalists and non-profits, represent a key constituency of TDM users.


[...] Any comprehensive strategy to make Europe globally competitive in the race to develop and implement AI-powered solutions must include robust support for TDM in both the public and private research industries, and not be reserved for very limited non-commercial public interest research projects. [...]

We specifically ask the JURI Committee to revise the exception for TDM as follows:

  • Broaden the scope of Article 3.1 to includeany person (natural or legal) that has lawful access to content, provided that reproduction or extraction is used for the sole purpose of text and data mining.
  • Support the European Commission’s proposal on article 3.2 to ensure that contractual terms restricting the use of the exception are unenforceable.
  • Clarify in Article 3.3 that technical measures cannot be used to unreasonably restrict the exception’s beneficiaries to conduct TDM.
  • Add a paragraph in Article 3 to allow datasets created for the purpose of TDM to be stored on secured servers for future verification.


Full text of the Open Letter [PDF]



List of original signatories -1

List of original signatories -2



List of original signatories




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