Subject: To the attention of Minister Liisa-Ly Pakosta: Open data of the Estonian language and META
From: "Wout Van Wijk" <[email-masked]>
To: "[email-masked]"
Cc: "[email-masked]"
Date: Mon, 10 Feb 2025 18:05:01 +0200

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

[signed copy of this letter in attachment]

Dear Madam Minister Liisa-Ly Pakosta,

News Media Europe took note of the Estonian Ministry of Justice and
Digital Affairs’ decision to provide Meta, the parent company of Facebook,
Instagram and WhatsApp, with the open data of the Estonian language
corpus[1], containing almost 4 billion words. We urge the Ministry to
reconsider its decision, or at least suspend it until the Ministry has
agreed with rightsholders, including news publishers, on the appropriate
framework for the use of their content by Meta under this deal.

News Media Europe recalls that any media content – including the content
archives of publications – is an important asset for publishers and that
copyright and related rights do apply. While we wholeheartedly subscribe
to the notion that the sustainability of the Estonian language and culture
needs to be safeguarded in the development of large language models, the
reality of the relevant legal frameworks and the protections offered
therein to rightsholders, cannot and should not be ignored.

Doing so undermines the legal rights and the financial sustainability of
editorial media, who contribute uniquely to the security of Estonia and
the EU by building information resilience against foreign interference and
manipulation, while underpinning the democratic processes.

In connection with this, we ask for information:

*	What data does the "Open Data of the Estonian Language Corpus"
contain, and more specifically, does it contain copyrighted content of
media companies (including members of the Estonian Association of Media
Companies), to what extent and in what form?
*	On what legal basis (incl. in the sense of AutÕS and IKS) was the
content in the above-mentioned dataset transferred to Meta (or, if this
transfer has not yet taken place, on what legal basis is it
planned/intended to transfer this content)?
*	Under what conditions was it agreed/planned to agree with Meta on
the use of language corpus content and what safeguards were taken by the
Ministry and/or other parties to the agreement to prevent unlawful use of
data (incl. in application outputs)?
*	What steps has the Ministry taken to protect the rights of
Estonian authors and owners of related rights in the content of the
database described above, to obtain their permission and to pay them fair
remuneration?  If the content of media companies was transferred/given to
Meta (and another developer of a large language model) without permission
and free of charge, how is it intended to remedy the damage caused by this
offence?

Thank you, Minister, for your kind consideration, and I remain at your
disposal for any enquiries you might have.

Yours sincerely,
Wout van Wijk

  _____

[1]
https://www.justdigi.ee/en/news/meta-interested-using-open-data-estonian-l
anguage-corpus

Wout van Wijk

Executive Director

NEWS MEDIA EUROPE

[email-masked] <mailto:[email-masked]>

 <tel:+32473685864> +32 473 685864

EU Transparency Register ID: 577812220311-81