This rationale seems to be consistent with the recommendation of the International
Intellectual Property Alliance (IIPA), which states that the ambiguous educational exceptions in
Section 32 of the Thai CA 1994 are the chief problem hindering the enforcement of copyright
protection in Thailand. 34 The report observes that the educational exceptions in Section 32 of
the Thai CA 1994 are poorly drafted and contain gaps which can be interpreted to allow the
photocopying of entire textbooks or substantial portions freely. 35 They thus lack a clear
limitation as to the amount of reproduction or clear prohibition of multiple reproductions and
fail to specify that photocopy shops making photocopies of published materials for students can
be held liable for copyright infringement. 36 Hence, it requested that this loophole be closed. 37