The second factor which makes it more problematic to safeguard the economic interests
of copyright owners was created by the IP Court in Decision No. 784/2542 . In this vein the
Thai Court has never made clear whether multiple reproductions of copyrighted materials are
lawful, pursuant to the educational exceptions. It creates two problematic approaches that
weaken copyright protection in the Thai education sector. The Court's first approach allows the
reproduction of entire textbooks under the exceptions for research and study, when the numbers
of the textbooks in the library were not available to match the numbers and the needs of students
or the price of books was unreasonably expensive. In its report, the IIPA states that Section 32
of the Thai CA 1994 creates an unclear and overly broad exception, which has been broadly
interpreted by the Thai courts to allow unauthorized photocopying of entire textbooks or substantial portions of published materials, as long as the copy is made for educational
purposes. 38