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=== Australia === {{Main|History of Fair Use proposals in Australia}} While Australian copyright exceptions are based on the Fair Dealing system, since 1998 a series of Australian government inquiries have examined, and in most cases recommended, the introduction of a "flexible and open" Fair Use system into Australian copyright law. From 1998 to 2017 there have been eight Australian government inquiries which have considered the question of whether fair use should be adopted in Australia. Six reviews have recommended Australia adopt a "Fair Use" model of copyright exceptions:<ref>{{Cite news|url=http://www.smh.com.au/comment/productivity-commission-to-say-fair-use-could-get-us-ahead-and-end-the-copyright-protection-racket-20161214-gtau3u.html|title=Our copyright laws are holding us back, and there's a way out|last=Martin|first=Peter|date=December 15, 2016|work=[[The Sydney Morning Herald]]|access-date=February 6, 2017|archive-url=https://web.archive.org/web/20161214223301/http://www.smh.com.au/comment/productivity-commission-to-say-fair-use-could-get-us-ahead-and-end-the-copyright-protection-racket-20161214-gtau3u.html|archive-date=December 14, 2016|url-status=live}}</ref><ref>{{Cite web|url=http://digital.org.au/content/productivity-commission-draft-ip-report-breakdown|title=Productivity Commission Draft IP Report – the breakdown|date=June 16, 2016|publisher=[[Australian Digital Alliance]]|access-date=March 7, 2017|archive-url=https://web.archive.org/web/20170220114151/http://digital.org.au/content/productivity-commission-draft-ip-report-breakdown|archive-date=February 20, 2017|url-status=dead}}</ref> two enquiries specifically into the Copyright Act (1998, 2014); and four broader reviews (both 2004, 2013, 2016). One review (2000) recommended against the introduction of fair use and another (2005) issued no final report.<ref>{{Cite web|url=https://www.alrc.gov.au/publications/4-case-fair-use-australia/reviews-have-considered-fair-use|title=Reviews that have considered fair use|date=June 4, 2013|website=www.alrc.gov.au|publisher=[[Australian Law Reform Commission]]|access-date=March 8, 2017|archive-date=December 21, 2016|archive-url=https://web.archive.org/web/20161221092927/http://www.alrc.gov.au/publications/4-case-fair-use-australia/reviews-have-considered-fair-use|url-status=dead}}</ref> Two of the recommendations were specifically in response to the stricter copyright rules introduced as part of the [[Australia–United States Free Trade Agreement]] (AUSFTA), while the most recent two, by the [[Australian Law Reform Commission]] (ALRC) and the [[Productivity Commission]] (PC) were with reference to strengthening Australia's "digital economy".
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