It says w/o evidence that "most" APC-based journals are #predatory.
It says incorrectly that US #copyright law bars scholars at some public unis from transferring copyrights to publishers. (Nearest thing: work by govt employees is uncopyrightable.)
It's aware of APC waivers but not no-APC OA journals (#DiamondOA), their numbers, & the many initiatives to foster them.
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