We turn now to the important question of what constitutes a ‘quotation’. Clearly, the breadth of the concept of ‘quotation’ will affect the scope of any quotation exception and so it is vital to identify what can be characterised as quotation. Our central argument in this chapter is that the concept of ‘quotation’ in Article 10(1) is far wider than the ‘typical’ case of textual quotation and that the attributes of ‘typical’ quotation must not be elevated to conditions for the availability of the exception.