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Google Australia Level 18, Tower 1 Darling Park 201 Sussex Street Sydney NSW 2000

Tel: 02 9374-4000 Fax: 02 9374-4001 www.google.com.au

protection does not create undue financial, technical and administrative burdens on industry. Further, the above proposal would not jeopardize the user experience that has seen consumers so readily embrace user generated content sites for uploading and accessing benign content, while ensuring that any higher level content is flagged when identified as such and appropriately access controlled.

  • Google makes a number of other, more detailed, suggestions for improvements of the draft RAS Declaration, in sections 6, 7 and 8 of this submission.

Detailed comments


Google Services

Google Australia Pty Limited provides marketing and technical support and representation in Australia for Google corporations providing the Google family of services globally. These service provider entities relevantly include Google Inc and Google Ireland Limited. We will use Google in this submission to refer to Google Inc and its subsidiaries, including Google Australia Pty Limited.

Google as an internet service provider initially became familiar to most to Internet users as the provider of the Google search engine and subsequently as the provider of email, instant messaging and specialist search and information services, including Google News, Google Finance and Google Maps.

Most recently Google (by acquisition of YouTube) became the provider of the well- known YouTube service. YouTube is a platform for people to watch and share original videos through a Web experience. By registering, users are able to upload and share videos, save favorites, create playlists and comment on videos, all for free. YouTube is a user generated content service that is made available as an ‘on-site’ – that is, following registration as a user, a user is able to upload content directly to the site without intervention or intermediation in relation to that content by Google YouTube staff. Any person may view content on the YouTube site without prior registration or payment of any charge.

YouTube is currently made available in Australia and many other countries from servers in the United States of America. Google does not currently host YouTube content in Australia.

YouTube presents content in tailored form for users from different countries. For example, the Google service provider entities currently provide YouTube service from sites including www.youtube.com, http://au.youtube.com, and http://nz.youtube.com , all serving content from USA based servers. These localized sites are a ‘sub domain’ of the YouTube.com site. The different YouTube sites use a common graphical user interface but have customised elements and rank and present content according to demand patterns at individual sites. Accordingly, although content available for viewing in most countries comes from a common pool and is presented through a broadly common graphical user interface, content displayed as

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