14. That the above failures of the 2nd Respondent’s to comply with the provision of the Copyright and Neighbouring Rights Act 2006 and the Regulations there under are breaches and an infraction of the law, regulations and quality of service requirement and render the 2nd respondent liable to sanctions imposed by the 1st respondent of cancellation of the Collecting License issued. 15. That further the above said failures of the 2nd respondent are a violation of the applicants’ and the general public’s rights as stakeholders and consumers of copyright services and render the systems operated by the 2nd respondent as unreliable, insecure, acts of un fair competition, inefficient and ineffective contrary to the legitimate expectations of the applicants and the general public as producers/film makers. 16. That the compilation, assembly, recording, producing, reproducing, translating, distributing, broadcasting, making available to the public, importing and downloading audio visual works by video hall vendors as authorized and licensed by the 2nd Respondents without authorization from the rights holders is an infringement of copyright, an act of piracy and conversion of the copyright holders’ property in such audio visual works. 17. That the 1st Respondent is fully aware and has knowledge of the impugned acts of the 2 nd Respondent breaching the copyright compliance, administrative mismanagement and quality of services requirement but has neglected and/or failed to take action to enforce compliance. The applicants shall rely on, inter alia, the correspondence between the various film associations and Uganda Registration Services Bureau in respect to the 2nd Respondent activities and mismanagement. 18. That the 1st Respondent has committed statutory breaches in so far as it has: o Allowed the other 2nd Respondent to continue operating without having audited books of accounts for Eight (8) years. o Allowed the 2nd Respondent to illegally operate when it commenced illegal and criminal activities of licensing copyright infringing Video hall vendors without any authorization whatsoever from the rights holders. o Failed to convene a special general meeting for electing a new executive committee for the 2nd Respondent upon realising the issues raised in 22(a) of my affidavit in support o Failed to cancel the Collecting Society License of the 2nd Respondent upon realising the issues in this application 5