[Jonathan Band] The documents provided to Knowledge Ecology International in response to its Freedom of Information Act request to the U.S. Trade Representative concerning the South African Copyright Amendment Bill (“CAB”) led to the discovery of a set of comments on the draft bill prepared by Michele Woods, Director of the Copyright Law Division of the World Intellectual Property Organization. These comments, dated October 1, 2018, in effect refute the central argument of the International Intellectual Property Alliance’s petition to USTR that South Africa should be denied U.S. trade preferences because the CAB, if signed into law, would not provide adequate and effective protection to intellectual property. Woods prepared these comments as a member of a panel of experts appointed by the Portfolio Committee of the South African Parliament to review the CAB. Woods stated that the comments reflected her views and are not official WIPO interpretations of international treaty obligations.