the three-step test and the WTO Panel decision are relevant to Thai copyright law because the second and third criteria of the test were incorporated into section 32(1) of the Thai CA 1994 as preconditions for specific exceptions and the exceptions in the list of permitted acts. Furthermore, The WTO Panel decision contains an interpretation of the three-step test which is viewed by many countries as a guideline on how to apply the test, therefore, if the exceptions under the Thai CA 1994 fail to comply with the test, then they may be subject to a challenge from other counties in the WTO dispute settlement proceeding, as in the WTO Panel decision WT/DS106