FOX International (Gabriella Dore) wrote to the European Commission:
The involvement of search engines and Internet Services Providers in the enforcement procedures should be considered necessary for the effectiveness of the protection of copyright. This would not necessarily imply legal liabilities for this kind of intermediaries, but it should at least provided a sort of duty of co-operation on these subjects. At the same time, Members States that would not introduce this kind of legal responsibility may be considered in breach of EU rules and sanctioned by EU institutions for this.
It feels a bit bad that a lawyer from a non-European company tells the European Commission how to trade laws on member states. This is not how it works.
Internet environment and audiovisual content copyright infringements usually bring a problematic approach in the evidence and proof of violation. Enforcement Directive should provide an evidence regime in favor of content provider and rights holder.