The Supreme Court of Canada had long established that fair dealing was user’s right that operated in balance with creator’s rights. The concern with anti-circumvention rules – which played out over several bills in Canada – was that rights holders could effectively limit the exercise of user rights by using technology to lock down copyright works. The classic example was that a user might be entitled to copy a portion of a chapter in a book, but if the book became an e-book with a digital lock, the publisher could use technology to stop copying that was otherwise permitted under the law. If the user sought to circumvent or by-pass the technology to assert their rights, that act of circumvention would itself become an infringement even if the underlying copying itself was permitted.