The Entertainment Software Association has filed a report with the U.S Trade Representative (USTR), highlighting issues of online and commercial piracy overseas that it says threaten the growth and development of the game industry. The report focuses on countries including Canada, China, Malaysia, Russia, and parts of Europe that the ESA says are primary in the issue. The special 301 filing includes enforcement deficiencies in Canada, pirate production for export in China and Malaysia, bureaucratic impediments to growth in China, and piracy production saturation in Russia, among other details. Additionally, the report notes Italy, Spain, Poland and Sweden as "among the most problematic countries with respect to online piracy, particularly through the use of peer-to-peer protocols. However, notes the ESA, online piracy is "extraordinarily high" in Brazil, Canada and China, in addition to Europe. Finally, the filing calls legitimate game sales "virtually non-existent" in Brazil and India due to high tariffs and additional taxes, and calls out Paraguay as a Latin American "pirate hub". The ESA said the countries it identified in the filing should be urged to bring their copyright and enforcement regimes up to international standards, and open their markets to legitimate products. ESA CEO Michael Gallagher said, "USTR has been a leader in the fight to protect America’s creative industries from the theft of our products. This year our Special 301 filing highlights countries that urgently need to begin backing up their commitment to creativity and innovation. We look forward to working with USTR and other supporting government agencies to achieve tangible results and hopefully succeed in lowering piracy in these key countries. Freeing these markets from the pirates’ stranglehold will also help empower a local video game economy."