What has been recommended is the graduated response process. There is a history of negotiation between the music industry and its representatives and the Internet service providers which I will go into. This process is also in operation in France and has been agreed in the Digital Economy Act in the United Kingdom. Finland and New Zealand have already agreed to pursue this route, while Korea has had a graduated response system in operation for some considerable time. The reason I say we must have some response - we cannot leave a lacuna - is that Mr. Justice Charleton identified the problem and indicated in a written judgment that Irish law was deficient. He has indicated that a solution lies in the graduated response approach to which I have referred. However, he is not in a position to enforce this or give injunctive relief because the European directive was, apparently, inefficiently and inadequately transposed into Irish law.