Opinion: IMDA Must Uphold Authors’ and Publishers’ Intellectual Property Rights

The Infocomm Media Development Authority (IMDA) of Singapore is planning to develop a new Large Language Model (LLM) that is trained on Singaporean sources. Building on the SEA-LION (South-East Asian Languages In One Network) family of LLMs, the new LLM aims to include accurate references to Singaporean places, colloquialisms, and culture, in languages that are commonly used in Singapore.
 
It has come to our attention that IMDA is looking to include local writings in training this new LLM. It has sent out a survey to ask for the input of authors, publishers, and members of the local literary community about this inclusion as, to quote the survey, “we recognise the delicate nature of this topic.” The survey asks those who are interested in taking part in this research project to leave their email addresses. It assures respondents that all data contributed will be used by IMDA-led research teams solely for research purposes. The survey form can be viewed here.
 
We find this survey deeply concerning for the following reasons:
 
1. The survey does not state anywhere that IMDA recognizes that the writings it is seeking are the intellectual property of the authors, or of the publishers to which the authors have sold the rights to their work. However, these writings are protected by existing contracts, and intellectual property and copyright laws. They may be not used by any research projects, public or private, without infringing on those rights and contravening those laws. As a state agency, IMDA should be very explicit about its commitment to uphold the rights of authors, translators, and publishers and the laws of the land.
 
2. The survey does not commit itself to paying fair compensation for the use of all writings. As the PEN International Copyright Manifesto puts it, “To deny authors the ability to earn monetary reward from their creative works is to deny the works value and their authors a livelihood. Using the intellectual property of an author without fair recompense, and in the absence of a legitimate legal exception to the author’s copyright, is theft.” Just as researchers, computer programmers, and civil servants involved in this project are paid for their work, so should authors, translators, and publishers be paid.
 
3. The survey was sent out on 28 March, and its deadline 7 April allowed for only 10 days to respond. Although the deadline has since been extended to 15 April, 18 days is still insufficient time for the proper gathering of feedback. Furthermore, it is unclear to whom the survey was sent. Although Singapore Unbound publishes Singapore literature through our press Gaudy Boy, we did not receive the survey but were alerted to it by a third party. Our friends in publishing based in Singapore told us that they did not receive the survey either. The limited duration and reach of the survey must unfortunately throw doubt on the effectiveness and fairness of the effort to collect genuine and thoughtful responses from the literary community.
 
There are important issues that go beyond this one survey. What will be the impact of the headlong rush to implement AI in business products on Singapore literature and culture? Or on Singapore’s economy, in particular, on jobs and employment? For instance, will the rapid implementation of AI nip the nascent activity of literary translation in the bud, or even devastate the sector of commercial translation? These are not wild surmises but hotly debated questions in the global literary community. More cultural, economic, and sociological research needs to be conducted and examined, in addition to the focus on technological advancement and business efficiency.
 
We call on IMDA to do the following:
 
(1) Acknowledge explicitly on project websites and materials that the country’s intellectual property and copyright laws, and existing contractual arrangements will be upheld in creating, researching, and training LLMs;
 
(2) Consult the different groups of stakeholders in the literary community (writers, translators, editors, publishers, etc.) through in-person dialogue sessions in order to field questions and get broad and deep feedback from the creators of our precious cultural heritage;
 
(3) Provide adequate funding for the literary community to obtain independent expert and legal advice. This gesture of goodwill would be much welcomed;
 
(4) Appoint an advisory board with legal experts and representatives of the literary community to determine the process and timeline for obtaining local writings for LLMs;
 
(5) Publish fair and transparent compensation rates for the use of writings owned by authors and publishers. Proper contractual agreements should be drawn up between IMDA and authors/publishers/rights holders; the latter should have the right to opt out of being a part of the research;
 
(6) Apply the above recommendations to its work on other Southeast Asian writings besides Singapore’s. Since Singapore has taken a pivotal role in developing LLMs for Southeast Asian countries and contexts, it must address the same concerns above in its use of other Southeast Asian writings, and not just Singapore's.
 
The work of authors, translators, and publishers in Singapore and the rest of Southeast Asia ought to be treated with due respect. It is not merely data for the machines, but the living tissue of our societies.
 
Editorial Board, Singapore Unbound

A transnational literary organization based in New York City, Singapore Unbound envisions and works for a creative and fulfilling life for everyone through the arts and activism.

The role of Singapore Unbound’s Editorial Board is to provide readers with a thoughtful and independent perspective on issues that resonate with our organization’s values. The Board also seeks to engage readers in a critical dialogue about important social questions by providing them with the information to make decisions and take actions for the common good.

The Editorial Board develops its positions on a variety of issues, but the views expressed are independent of the rest of the organization. Editorials are unsigned to reflect the fact that they represent the collective views of the Board instead of any individual member.

Jee Koh