- in support of motion for leave to intervene (without exhibits)
- McGill Centre for Intellectual Property Policy filed in the SCC case  3 SCR 615, 2015 SCC 57, wherein I appeared along with Prof. David Lametti, as he then was, and Prof. Ariel Katz. Based upon our argument, the Court, per Rothstein J., ruled that:
 I conclude that the statutory licensing scheme does not contemplate that licences fixed by the Board pursuant to s. 70.2 should have a mandatory binding effect against users. However, this case does not require this Court to decide whether the same is true of collective organizations. It may be that the statutory scheme’s focus on regulating the actions of collective organizations, and the case law’s focus on ensuring that such organizations do not devolve into “instruments of oppression and extortion” (Vigneux v. Canadian Performing Right Society, Ltd., 1943 CanLII 38 (SCC),  S.C.R. 348, at p. 354, per Duff J., quoting Hanfstaengl v. Empire Palace,  3 Ch. 109, at p. 128) would justify finding that the Board does have the power to bind collective organizations to a licence based on the user’s preferred model — transactional or blanket — on terms that the Board finds fair in view of that model. However, this issue was not argued in this case.
 I find that licences fixed by the Board do not have mandatory binding force over a user; the Board has the statutory authority to fix the terms of licences pursuant to s. 70.2, but a user retains the ability to decide whether to become a licensee and operate pursuant to that licence, or to decline.