A principal theme of the first section of this book is that one of the major difficulties with the United Kingdom's present approach towards the exceptions is that it lacks flexibility. It was seen that in large part this is because the United Kingdom has a list of very specific exceptions, encompassing carefully defined activities. With the benefit of hindsight, it is possible to point to the Copyright Act 1911 as providing the template for this approach. This is particularly significant because the 1911 Act was an imperial measure. Although most former colonies and dominions have now had their own copyright legislation for a considerable number of years, for the most part this legislation has tended to follow the imperial model developed in 1911. Thus Australia, Canada, India, New Zealand, Singapore and South Africa delineate the limits of copyright protection by way of an exhaustive list of specifically defined exceptions. This ‘Commonwealth’ approach is often contrasted with that adopted in the United States. Although US law does contain a number of specific exceptions, it also has a general ‘fair use’ defence, contained in section 107 of the Copyright Act 1976. Although this section provides a list of examples of the types of use that may constitute fair use (including, for example, criticism, comment and research), this list is merely illustrative.