Most international copyright treaties allow their contracting countries to have different
copyright exceptions in their national copyright laws in order to maintain their own unique
equilibrium. The problem is that this balance of protecting the economic interest of copyright
owners in order to encourage incentives for creativity and serving public interest in the
dissemination of knowledge through the copyright exceptions cannot be easily achieved.15 This
is because the point of the balance can be different in each country, depending on a state's
underlying philosophy and objectives for copyright protection.16 Guibault explains that the
copyright exceptions should reflect the need of society to use a work, balanced against the
protection on the economic interest of copyright owners. However, this weighing process
usually leads to different results in each country, since the potential conflict between the
interests of copyright owners and the public interest can take place at different levels and
grounds in each country.17 This difference stems from the legislator’s assessment of the
importance of a particular exception for society in relation to the need to provide for the
payment of an equitable remuneration to the copyright owners in order to maintain incentives
for creativity.18 The outcome of this evaluation will most often determine the form of the
exception.