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The following statement may be attributed to John Bergmayer, Senior Staff Attorney:
"It may make good business sense for Google to take extraordinary steps, far beyond what the law requires, to help the media companies it partners with. That said, its plan to penalize sites that receive DMCA notices raises many questions.
"Sites may not know about, or have the ability to easily challenge, notices sent to Google. And Google has set up a system that may be abused by bad faith actors who want to suppress their rivals and competitors. Sites that host a lot of content, or are very popular, may receive a disproportionate number of notices (which are mere accusations of infringement) without being disproportionately infringing. And user-generated content sites could be harmed by this change, even though the DMCA was structured to protect them.
"Google needs to make sure this change does not harm Internet users or the Internet ecosystem."