ACT position on contracts for the supply of digital content

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We would like to bring to the attention of the institutions some concerns the ACT has in relation to the draft proposal for a Directive on certain aspects concerning contracts for the supply of digital content (“the Proposal”).
The submission addresses the following issues specifically:
A. Burden of proof
B. Digital Content definition
C. Digital Content provided for in kind data
D. Conformity of the Digital Content with the Contract
E. Modification of Digital Content
F. Termination obligations on Traders and Consumers (right to reject)
G. Restriction of contracts to 12 months