Besieged, Bothered and Bewildered - Our Book Industry Feels the Pain

Besieged, Bothered and Bewildered - Our Book Industry Feels the Pain



(Article for The Rationalist journal, January 2011)


You cannot open a paper these days without coming across yet another article about the huge increase in purchasing from overseas-based online retailers by Australian consumers in response to the strong dollar. Books are always the prime example. The local book industry is under siege and booksellers and publishers are barely talking about anything else.


Amazon has been doing good business out of Australians for over a decade now, but has been joined in the last twelve months by The Book Depository, the UK operation that matches Amazon’s prices and discounts but also offers free freight, an appealing combination.


It’s virtually impossible to get a handle on just how much business these two do in Australia (Amazon in particular has never felt inclined to part with any information that could be remotely useful to anybody), but anecdotally industry insiders are now estimating that the business could be upwards of $200 million and rapidly rising. The total consumer book market in this country, at retail level, is about $1.6 billion (yet another difficult figure to pin down since the ABS stopped collecting book industry data six years ago). So the local industry is currently losing 12.5% plus of its turnover to offshore suppliers. It could well be 20% in five years time if things continue the way they are (and this is not counting library purchases from overseas library suppliers – another huge chunk).


Our book industry is having its own ‘annus horribilis’, with most independent bookstores experiencing sales declines of between 5-10% compared to last year. REDGroup Retail, the Angus and Robertson and Borders chains, with a share of about 30% of the total Australian consumer book market, had a sales decline of 11% for their fiscal year ending August, 2010. This amounted to $70 million. They also slashed their inventory holding by $50 million, which means they studiously declined to order from publishers and dumped unsold stock back to them where they could. You can imagine the effect on publishers and authors.


The book trade has always been a very emotional one – part art, part commerce, and totally cottage. But the heightened level of emotion and anger coursing through industry veins right now is something to behold. And it’s very typical in any industry in these circumstances to see its players develop a siege mentality, bunker down, lash out at foreigners, and resort to some fairly ordinary thinking and analysis quite typical of victims.


To get some perspective let’s go back two years. In August 2008 the Rudd government decided to hold yet another enquiry into books and parallel importation, the provisions in our Copyright Act that prohibit retail booksellers from ordering direct from overseas any title for which a local publisher holds, under contract, exclusive Australian rights. In the trade this activity is known as ‘buying around’. The government imagined there could be some political gain from overturning this century-old prohibition in the interests of allowing cheaper prices to flow to consumers. The Productivity Commission, for the third time in twenty years, was charged with examining the issue and making recommendations.


Well, as we know, to no-one’s surprise, the reaction from the industry was swift, uniform and very angry. Of the 563 submissions to the enquiry, all but a dozen of them were in favour of retaining the current restrictions. No ifs, no buts, the Visigoths must not be allowed to have their way. Australian literary culture would be decidedly poorer. The Commission’s final report, however, recommended what the commission had always recommended – that the restrictions should be abolished in favour of a better deal for the consumer. Typically, the Rudd government was frightened off, so reform never happened.


So after a highly charged year of fighting and fending off, the book industry relaxed, luxuriated in victory, and resumed business as usual. It was to be a major mistake. What had actually been happening in recent years, and what the Productivity Commission expertly analysed and measured, was a growing uncompetitiveness in the protected, privileged publishing community in response to the ever-stronger Australian dollar, a massive over-pricing that could never be commercially or realistically sustained. The Visigoths already had a foot in the camp and no artificial, protective, legal mechanism could keep them out. They were called Amazon and The Book Depository. And the consumer, whose interests were ignored in the parallel importation decision, had noticed.


The Australian Publishers Association (APA), in their long, furiously angry and sniffily dismissive response to the Productivity Commission’s draft report, denied that their members had ever over-priced, and if they ever did they were certainly not doing it now. They contended that the average A$/US$ exchange rate over the previous ten year period was $0.69, so it was entirely reasonable for local publishers today to use this rate or something close to it in their pricing for the Australian market. This submission was written when the dollar had hit $0.90! As I wrote at the time:


‘Today, as you know, [the dollar] is around $0.90c, and against the pound it’s the highest it’s been for 25 years. Publishers have had five or six years now to adjust to exchange realities but most have chosen not to do so. How long is the Australian consumer supposed to wait? Booksellers, on the other hand, have to compete with Amazon, which uses the exchange rate operative on the very day of invoicing. Not surprisingly, they are finding it hard to compete.’ (1)


Had the government decided to accept the Commission’s recommendations and abolish the provisions, the competitive pressures unleashed in the deregulated market would have been fairly intense. This is basically what would have happened:


1. Booksellers would have radically stepped up their ‘buying around’ behaviour, in order to source product overseas at lower wholesale prices so they could price lower to their customers than local publishers’ recommended prices, and thus compete more effectively with online suppliers.


2. To head this off publishers would have quickly lowered their prices and possibly sweetened their trading terms to regain the business. If they were serious about it, and went far enough, they would have recaptured virtually all the former business they had.


3. Since booksellers much prefer to order locally, all other things being equal, because there’s less risk and hassle involved, things would have got back to a new normal pretty quickly. And territorial rights would have been re-respected.


4. The consumer would have won.


5. In fact everyone would have won because of the new vitality injected into the industry. Intense competition tends to do that. (Even the printers in Maryborough, who thought the end of the world was nigh, would have won).


So the Rudd government – and how typical was this? – stuffed up big time. The only crumb they threw the industry was to set up a Book Industry Strategy Group (BISG) under the auspices of Senator Kim Carr’s industry and innovation department. This group was to recommend to the government how the industry could be helped to survive!


So having dispensed with a real solution that focussed on the real problem, the industry gravitated to familiar ground: campaign for the GST to be applied to purchases from Amazon and their ilk. This would ‘level the playing field’, and presumably solve most if not all of our problems. Under the GST system as it currently operates any purchases from overseas suppliers escape the GST net if they are below a $1000 threshold. The reason for this is to not bog down individuals in customs red tape and delays for minimal net revenue gain. In fact, the government’s advisory body on taxation matters, the Board of Taxation, recommended to the government in February of this year that any lowering of this threshold, despite the clamour from various retail associations to lower it to $250, would be counter-productive (2). The government agreed. (By the way, even this lower threshold would not capture 99% plus of book purchases!)


The Australian Booksellers Association’s (ABA) official position is to continue to advocate for a much lower threshold, or if that were not a goer, for the removal of GST from books altogether.


A few basic things need to be said:


1. There is no chance whatsoever of any government removing the GST on books. It’s really silly to even contemplate that, and it looks silly and ignorant to publicly campaign for it.


2. There is no chance whatsoever of any government lowering the threshold to below $250. The outcry from consumers would be loud and long. The GST is a tax system, not a job creation or protection system.


3. Even if by some remote chance the GST net was widened to capture these online purchases, then – and this is important – it would have minimal effect on book importing behaviour! The GST is still only 10%.


The other big retail chain in Australia, Dymocks, who to their credit did appreciate the main game and campaign for the opening of the market during the parallel importation debate, have recently come out and ‘threatened’ to move their online business offshore if the government did not change the GST rules. According to CEO Don Grover ‘It would actually make more sense for us to send books from an overseas location back to Australia and avoid the GST. To give a competitive advantage to overseas websites of 10% is just unsustainable’ (3).


Here is further evidence, if any were needed, that the current GST obsession of the Australian book trade is becoming deeply farcical. What about Australian books? Are they going to be shipped offshore and then re-shipped to the customer in Whyalla?


It’s only 10%. It’s utterly irrelevant. It’s not the main game. Publisher over-pricing is the main game, and the lack of any vigorous domestic competition to that practice. Here’s a simple test for any book buyer to apply: find out the overseas list price (Amazon’s a good source); convert to Australian dollars at today’s exchange rate (parity as I speak); add 10% (as a currency hedge); add another 10% for the GST; round up to the usual 95c price point. Then compare this to what the publisher is asking you to pay in your bookstore.


So George Bush’s just released Decision Points should be priced in this country at A$42.95, not $59.95 as it is. The US price is US$35.00. Do the math! Or take the Booker winner The Finkler Question: this L13.00 title should be $25.95, not $32.95 as it is. These aren’t isolated examples. They are commonplace. (In fact, be suspicious of any book priced at $32.95. If it’s an Australian original it should be $29.95, but if it’s a UK original, complain).


Screwing your customer is not really a productive and lasting strategy for any industry, but unfortunately it’s precisely what the publishing industry, aided by compliant and dependent booksellers, has long indulged in. Trying to slap a GST on Amazon and The Book Depository is a classic iteration of this - clobbering booklovers and serving to bolster dated, uncompetitive local pricing practices that are doing enormous structural harm to the industry.


We’re seeing precisely the same thing happening in the emerging ebook business. 2010 was the year Apple released the iPad and rolled out the ‘Agency Model’ for ebook pricing. This ‘app’ model may be fine for all sorts of products but not for books. It gave pricing power to the publisher, and prohibited the retailer from selling below the publisher-set price. Up until this time Amazon’s Kindle dominated the global ebook landscape (it still does, but it’s gone from about 90% to 65% in market share over the last two years). Amazon set ebook prices at levels way below what publishers thought they should be, so publishers jumped at the chance to force Amazon onto Agency pricing contracts. The five large US trade publishers, who carry enormous heft in the consumer market, forced Amazon to buckle by refusing supply unless they did. This model was also rolled out in the UK in October/November, 2010, and Hachette, Australia’s largest trade publisher, has just rolled it out here in Australia. Other major publishers are expected to follow. (By the time you read this they probably would all have signed up. Such is the way these things work).


The logic of the Agency model of supply is to keep pricing power in the hands of the publisher and away from retailers. Retailers are expressly forbidden under contract to offer their customers a lower price, even if only for a short time for promotional purposes. Now I keep banging on about this in the industry, but let me repeat it here: in Australia the agency pricing model is clearly and unambiguously AGAINST THE LAW! No doubt Hachette and other publishers have legal advice to the contrary. Well bugger me – legal advice that corroborates with what you want to do anyway! Who would have thought?


Here is what the ACCC says about Australia’s Resale Price Maintenance provisions in our Trade Practices Act. It’s pretty clear:


Any arrangement between a supplier and a reseller that means the reseller will not advertise, display or sell the goods the supplier supplies below a specified price is illegal.


It is also illegal for a supplier to cut off, or threaten to cut off, supply to a reseller (wholesale or retail) because they have been discounting goods or advertising discounts below prices set by the supplier.


A supplier may recommend an appropriate price for particular goods but may not stop retailers from charging or advertising below that price. In most cases, a supplier may specify a maximum price for resale. (4)


This is a succinct summary of what the actual provisions say. And why is this sort of thing illegal? Because it is anti-consumer. It denies the consumer the power to shop around to avoid being ripped off. It structures a producer-controlled market, where the producer is protected from unwelcome retail pressures for better terms that enable retailers to offer more attractive terms to their customer base.


And here is the interesting point: the expressed intentions of the publishers are to create a ‘level playing field, to enable retailers other than the dominant Amazon to be able to enter the market and compete – ensuring a better outcome for all players’. Very noble, but this sort of talk fools no-one. It’s code for smothering competition, not enhancing it. It works to the benefit of the publishers and against the interests of the consumers. Even that venerable old UK trade journal The Bookseller is becoming increasingly worried about what publishers think they’re doing: ‘At an instinctual level, whatever the sophistry employed in its defence, bringing in price fixing online will feel wrong to the only people who ultimately matter in this, the readers’ (5).


Finally, let me say something about territorial copyright, that beast that haunts the Australian trade and poisons so much of our debate. It was never the central issue in the parallel importation fracas, although most industry people, particularly authors, framed it so. It’s always been the source of enormous conceptual confusion, and I must say, with profound regret, continues to be so in the ebook world.


Most Australians who own an ebook reader are drearily familiar with the following message:


        This title is not available for customers from:
                              Australia
          Shop for titles available for Australia


What this means is that publishers have shoehorned Amazon, Apple, Sony, Kobo, Google and other ebook retailers into honouring the territorial rights deal the publisher has made with the author, or more accurately, the author’s agent. If a US publisher has only bought US rights then its ebook contract with etailers will only entitle those etailers to sell to Americans. And here’s the rub: even if no Australian rights (or, more frequently, Commonwealth rights) have yet been sold by the agent, then still no Australian consumer can buy that ebook.


To me this is an offense against logic and fairness, and runs entirely counter to the long and established conventions of the retail trade, and it certainly runs counter to what happens in the analogue book world. If I order from Amazon the US edition of a print book for which Commonwealth or Australian rights have been sold, I will still be supplied it. There is no publisher ‘contract’ that restricts Amazon from supplying it to me. In fact the US, UK and Australian Copyright Acts have long embraced the concept of the ‘first sale doctrine’, which means publisher rights over the product are exhausted after the first sale. The retailer can do what they like with the book – give it away, discount the buggery out of it, sell it to China – without being answerable to the publisher. They are only restricted from making copies of it. This convention enshrines a free space for retailers outside the usual restrictions of copyright law and underpins a vital commercial role in information distribution.


In the e-world, however, it seems we’ve gone backwards. Ironically, when it is so much easier to distribute globally a digital file than a heavy, physical object, we’ve been lumbered with publisher timidity and myopia yet again. There is a simple and practical solution though, which I’ve urged on my publisher colleagues. Make ebooks available from day one to everyone around the globe no matter where they live. The original ebook publisher could do this by not territorially constraining etailers. And when rights to a particular territory end up being acquired by another publisher, then hand over those revenues to them. It would be simple to administer. Thus publishers buy a share of global revenues, not rights to a file.


Ah, much new thinking, much water to go under the bridge yet. Old habits die hard in the book industry. Even when the readers are walking away. If only publishers would reach out to them, befriend them, listen to them, try to satisfy them. They may find they’re not that scary. And they may also find they return the compliment.





NOTES

1. ‘The Parallel Importation Debate – Thank God the End is Nigh!’ Peter Donoughue; p. 61, Copyright Reporter, Journal of the Copyright Society of Australia, June 2010.

2. ‘Review of the Application of the GST to Cross-Border Transactions’, p. 46, The Board of Taxation, February, 2010.

3. ‘Book Battle: Dymocks Considers Offshore Option’, Nicole Chettle, ABC News, November 18, 2010.

4. http://www.accc.gov.au/content/index.phtml/itemId/322982

5. ‘Expensive Model’, p. 3, The Bookseller, London, November 5, 2010.

Dymocks offshore threat... Pleeeze!

Here's the ABC news report:

http://www.abc.net.au/news/video/2010/11/18/3070096.htm

Don Grover's threat to move Dymock's online business offshore to escape the GST net is further evidence, if any were needed, that the current GST obsession of the Australian book trade is becoming deeply farcical!

Firstly, what about Australian books? Would Dymocks have Australian publishers ship them to Hong Kong so Dymocks can re-ship them back to the customer in Whyalla?

Well, perhaps Australian publishers would drop ship to Whyalla and Dymocks simply invoice the customer out of Hong Kong, thus saving on freight? Nope, won't work. Any supply from an Australian company is within the GST system and Dymocks won't get GST credits unless it charges the GST to the ultimate customer.

Well, perhaps Dymocks will only ship imported books from Hong Kong, with Australian titles coming from the Australian operation on a separate invoice? Very clumsy and confusing to customers, and how will the many local printings of overseas titles be handled, and local editions where local rights have been acquired?

I'm afraid whatever way you look at this it's a dud idea. The perfect case of a bad idea leading to a bad business strategy.

Don, it's only 10%. It's utterly irrelevant. It's not the main game. It's far from forming the basis of a radical avoidance strategy, which can only incur innumerable additional costs and bog you down in logistical dead ends. Your online business draws inventory from your main, richly and superbly stocked store in George St, Sydney. Divorce the two and both will surely and immeasurably suffer. I cannot believe otherwise. 

Focus on the main game - publisher over-pricing. And revisit the prohibition on parallel importing. That's still the elephant in the room.

Pricing in an Age of Parity

Old habits die hard in the book trade in Australia, but some habits to do with the way publishers have long priced imported titles are going to have to radically change if customers are going to be lured back into buying from Australian booksellers rather than Amazon or The Book Depository.

There are three issues:

1. Pricing way out of kilter with TODAY'S exchange rates.
2. Price points that lock in uncompetitive markups.
3. Infrequent price changes.

Bookbuyers are aggressively responding to the current parity paradigm by buying from overseas-based online retailers, and this is one of the principal reasons retail booksellers are really struggling at the moment. Conditions have rarely been worse. Consumers have gone way beyond the ROBO phenomenon (research online, buy offline) that's been with us for the last decade or so. Now it's just BO - buy online. There's no need to even research it, just do it. The ingrained expectation is that, even if the local bookseller has it in stock, the price will be way over the top.

This mindset can be broken, but only if publishers take radical action along the following lines:

- Price to current FX realities, not some dated average over the previous year or, god help us, decade. That means using parity for US titles and around 62p for UK titles, not just for forthcoming titles, but all titles currently being sold.

- Abolish pricing up to the closest traditional price point - $26.95; $29.95; $32.95; $35.00; $49.95; etc. There is too wide a gap between these points, and too many customers are dropping off on the way up. This was not much of an issue in times past, but it is today.

- Change prices frequently according to FX movements up or down. It's time to let go of the traditional three month's advance notice to retailers, and rarely, if ever, changing the backlist. Systems and protocols have to change. Monthly adjustments across the board should be the norm.

The golden rule on pricing should be: Today's exchange rate plus 10% plus GST. Thus a 13.00 pound UK title becomes A$25.37. Rounded up to the nearest 95c point, it becomes $25.95. A US$26.95 book becomes A$32.61, which becomes $32.95.

The reason for the 10% markup prior to the addition of the 10% GST? To build in a hedge for exchange volatility. Pricing at one rate and actually paying your overseas supplier at a possibly disadvantageous rate three or more months later can be a real problem for importers. Hence the hedge. The Australian dollar climbs via the stairs and falls via the lift well, as they say!

And what about freight? Here's another golden rule: booksellers pay freight when they import directly, not publishers. Publishers have it built into their intercompany or agency trading arrangements. In other words longer discounts or their equivalent are built in to recognise the additional impost of shipping to Australia.

So George Bush's just released Decision Points should be available in Australia for A$42.95, not $59.95 as advertised! The US price is US$35.00. Do the math!

And all those 13.00 pound UK titles, such as Philip Kerr's new one, Field Grey, should be $25.95, not $32.95 as it is. And Howard Jacobson's The Finkler Question (TPB edition) should be $25.95, not $32.99 as it is.

Pressure needs to be put on publishers to be far more responsive to today's competitive realities. And here is precisely where the ABA needs to step up. Real leadership is called for.

Don't hold your breath!

The Agency Model in Australia - wtf??

This distressing piece was in the WBN yesterday:


Hachette Australia CEO Malcolm Edwards has confirmed the publisher has signed with both the iBookstore and Kobo under ‘an agency agreement', but declined to comment on the publisher's pricing strategy.



Under the agency model agreements between Apple and publishers currently in use in the US and UK, publishers set the price of their ebooks and discounting by retailers is not allowed.


The Weekly Book Newsletter understands that Hachette Australia is the first publisher to come to an agency agreement with Kobo, however other publishers may also come to an agency agreement with the Canadian-based ebook distributor in future.


However Malcolm Neil, communications manager for REDgroup Retail which offers ebooks through the Kobo platform, said that ‘observing the situation in the UK, if publishers do move to an agency model in Australia in future, it will take a while for [associated price changes] to wash through the market'.


I know I keep banging on about this, but let me repeat: in Australia the agency pricing model is clearly and unambiguously AGAINST THE LAW!


No doubt Hachette has legal advice to the contrary. Well bugger me - legal advice that corroborates with what you want to do anyway! Who would have thought? (Although I'd love to see the hedging in that advice!)


Here is what the ACCC says about our Resale Price Maintenance provisions in our Trade Practices Act. It's pretty clear:

Any arrangement between a supplier and a reseller that means the reseller will not advertise, display or sell the goods the supplier supplies below a specified price is illegal.



It is also illegal for a supplier to cut off, or threaten to cut off, supply to a reseller (wholesale or retail) because they have been discounting goods or advertising discounts below prices set by the supplier.


A supplier may recommend an appropriate price for particular goods but may not stop retailers charging or advertising below that price. In most cases, a supplier may specify a maximum price for resale.


This is a succinct summary of what the actual provisions say.

One source of publisher confusion could be that Apple has thousands of Apps that have been legally supplied under the agency model in Australia since day one, so an Apple ebook is simply one more App. But 99.9% of those Apps are Apple exclusive and specific. The problem comes when other competing resellers get into the act and producers/suppliers attempt to force the model onto them. This is the danger with ebooks, which are far from being Apple specific. They need to be available on multiple devices. And foisting price control on them is restrictive of competition.

In Hachette's case they've gone to Kobo and presumably muscled them into meekly submitting. How bad is that?

This is dangerous legal ground. You really don't have to be Einstein (was he a lawyer?) to know that.

The GST and Online Retailers: the ABA's bad campaign

This appeared in the WBN yesterday:
GST-free online purchases a growing concern for booksellers:


Australian booksellers are among a growing number of Australian retailers who are calling on the federal government to reform the rules guiding the application of the GST to online purchases from international retailers.


Inside Retailing Online reported last month that the Australian Retailers Association (ARA) has been 'stirred into action' by a 'groundswell' of concern among its members about increasing numbers of Australian consumers purchasing cheaper goods online which do not collect GST.


Goods coming into Australia which are valued under $1000 are currently exempt from GST, and are therefore sold at cheaper prices to their Australian equivalents. The ARA estimates that the sale of these goods is costing the federal government approximately $600 million in lost revenue.


In recent weeks, Australian consumers have been given added incentive to purchase goods online with the strength of the Australian dollar against the US currency.


President of the Australian Booksellers Association Jon Page told the Weekly Book Newsletter that more consumers are choosing to shop online for books because of the strong Australian dollar, which is compounding the problems faced by the bookselling industry because many overseas books do not attract GST.


Page said that the application of the GST on books in Australia has had a significant impact on the industry, with book prices rising almost 33% since its introduction. Page said that booksellers 'are going to continue to be disadvantaged' as long as GST is not being collected on most overseas books purchased by Australian consumers.


'Most book orders consist of 2-5 books, which is well under the [$1000] threshold,' said Page. 'For there to be any impact on books being imported into the country, this threshold would need to be reduced significantly or the GST removed from books in Australia,' he said.


Similar sentiments were also expressed by ABA chief executive officer Joel Becker who told the Weekly Book Newsletter that the ABA expects the issue will be raised in many individual submissions, as well as their own, to the Book Industry Strategy Group.


Becker said that Australian booksellers are faced with 'an unfair impediment' when competing with overseas booksellers as they are effectively required to charge 10% more than international retailers before any other concerns are factored in.


Becker said that the issue is about more than just lost tax revenue for Australian governments, with significant flow-on effects on employment levels in the industry and in severe cases, the closure of businesses.


Becker told the Weekly Book Newsletter that the problem could be resolved in one of two ways.


The first option, said Becker, is to 'go back to what was supposed to happen before... the Australian Democrats went belly up to the Howard Government, and do not charge a GST on books'.


'Or if the government, in spite of having been opposed to a GST on books when in government and, later, in opposition, accepts that there should continue to be a GST on books, then introduce fairness into the process by charging GST on cross border purchases,' said Becker.


'All that we ask is that fairness and equity come into play,' he said.




This whole obsession with trying to get the GST applied to books imported online is pathetic on a number of counts.

Here are the facts:


1. The government reviewed the GST regulations governing imports as recently as February this year. The investigation by the Board of Taxation concluded that, if the current $1000 threshold were lowered to $250 as recommended by retail associations, 'there will be an increase in administrative costs of bringing more goods into the customs system in order to account for the GST which is likely to outweigh any benefit....[consumers would be] paying disproportionately high amounts of GST and administrative charges to have their goods released from Customs compared to the value of the goods' (p.46).


The Board concluded that, at the far lower threshold of $250 (no organisation was proposing it go any lower) the case had no merit. When you consider that most consumer book purchases from Amazon or The Book Depository would be well under that amount - 99% at least, I'd venture - then the case doesn't even get off the ground! 


The ABA, and booksellers generally, ought to appreciate the following:

1. There is no chance whatsoever of any government removing the GST on books. It's really silly to even contemplate that, and it looks silly and ignorant to publicly campaign for it.

2. There is no chance whatsoever of any government lowering the threshold to below $250. The outcry from consumers would be loud and long. The GST is a tax system, not a job creation or protection mechanism.

3. Even if by some remote chance the GST net was widened to capture these online purchases, then - and this is important - IT WOULD HAVE MINIMAL EFFECT ON BOOK IMPORTING BEHAVIOUR! Despite the humorous 33% claim of Jon Page above, the GST is still only 10%!

4. By far the most critical issue is the way consumers are forced offshore by the over-pricing of imported books in this country through publisher markups way out of line with foreign exchange realities. And now we're at parity, the situation is worse than ever. Having joined publishers to save them from having to face real competition through parallel imports last year, the ABA is reduced to this absurd focus on the GST because they've nowhere else to go.

5. The booksellers ought to take the fight to where it really belongs - up to the publishers and their outrageously outdated markup policies. The days of imported $32.95 TPB's and $40-50 HB's are well and truly over. It's way past time the pricing nexus between local titles and imports was broken.

Step up Jon and step up Joel. You know what you have to do. Stop being nice.