“A Dynamic Opportunity for Change”
: Colonial Echoes in Park Chung-hee-era Film Policies and Their Implementation
Keung Yoon "Becky" Bae (Dept. of East Asian Languages and Civilizations, Harvard Univ.)
A great deal of scholarship already exists in both Korean and English-language literature concerning the history of Chosŏn and Korean film policy throughout the twentieth century. Kim Kim Yŏ-sil painstakingly traces the footsteps of colonial-era filmmakers and their exchanges with the Japanese colonial government; Kim Tong-ho et al.’s exhaustive Hanguk Yŏnghwa Chŏngch’aeksa provides detailed analyses of Korean film legislation and their impact era-by-era; Yang Kyŏng-mi provides an important perspective of Korean film history by viewing it through the lens of the screen quota system. Amidst these plentiful works, however, there still seems to be a lack of comparative scholarship, be it temporal or geographical; indeed, many books and articles seem content to focus on the particulars of a specific film policy and its immediate influence on the film industry, rather than attempting to draw longer, more complex lines between more distant dots. And on occasions that comparative claims are made – such as that by Kim Mi-hyŏn in Hanguk Yŏnghwa Chŏngch’aek kwa Sanŏp, where she states that ‘the Motion Picture Law, enacted in 1962 and enforced for about 34 years until 1995, was a legislation that covered the era of military dictatorships, and was limited by the fact that it was based on the Chosŏn Film Decree from colonial times’ – these claims are not necessarily supported with specific examples.
My paper investigates Kim’s claim by first analyzing the key characteristics of the 1940 Chosŏn Film Decree enacted by the Governor-General of Korea, and then examining the Motion Picture Law and its Revisions during Park Chung-hee’s 19-year rule. Over the course of this investigation, I demonstrate that not only does some of the Park regime’s legal strategies in the film sector closely mirror those of the Governor-General in the 1940s, but also that the two governments’ exchanges and interactions with civilian film organizations (primarily filmmaker associations) also exhibit striking similarities. While my goal is not to argue that the Motion Picture Law was a direct and complete copy of the Chosŏn Film Decree, it is clear from this comparison that there are important commonalities in the problems that these respective eras’ governments and filmmakers faced, the goals that they tried to achieve, and that these commonalities ultimately contributed to the creation of ‘colonial echoes’ in the implementation of the Park regime’s film policies.
- 1939-1945: The Chosŏn Film Decree (Chosŏn Yŏnghwaryŏng朝鮮映畵令) and the ‘New Film Order’ (Yŏnghwa Shin Ch’eje映畵新體制)
In this section, I will first break down the measures delineated in the 1940 Chosŏn Film Decree, the organizations involved in its execution, and the impact that the Decree had in shaping – revamping – the Chosŏn film industry. I will demonstrate how this revamping was directed primarily by the Governor-General of Korea, but also aided and influenced by various Chosŏn film organizations of this period.
The Creation of the New Film Order
The earliest regulatory body for motion pictures and performance art began as early as the mid-1900s, with the Japanese Resident-General’s establishment of the Exhibition Supervision Rules (hŭnghaeng ch’wich’e kyuchik 興行取締規則) and the 1907 Security Law (poanpŏp保安法). Kim Yŏ-sil writes that, at this time, the regulation of film and performance was primarily conducted by the police force, though what was examined and censored were film plot summaries rather than the films themselves (as police stations did not own film projectors). Entering the 1920s, as the Governor-General shifted their mode of rule into bunka seiji (Cultural Rule), the regulations became more specific beginning in the Kyŏngsong area, with the police being authorized to vet film scripts, film reels, and also pyŏnsa activities. These regulations were nationally expanded in 1926, with the announcement of the Motion Picture Film Censorship Rules (hwaltong sajin pillŭm kŏmyŏl kyuchik), and the responsibilities were transferred from the police force to the body of the Governor-General itself. Kim asserts that the Governor-General would have felt the need to more directly censor films, as 1926 was the time when Chosŏn domestic films began to be produced in earnest.
It was not until 1940, however, when regulations that would assimilate cinema and the film industry into the machinery of governance would be established. Following the advent of the Second Sino-Japanese War in 1937, the GGK passed down orders to actively utilize films in the transition to a wartime regime, making requisite the projection of newsreels and GGK-produced war propaganda in film theaters; they signaled the advent of a new regime in film by naming the new regulations the ‘New Film Order’. Moreover, with the Japanese government’s decision to allow recruitment of Chosŏn people into the military for the Sino-Japanese War, also came the decision for the Governor-General to completely take over the Chosŏn film industry in terms of production and distribution, leading to the announcement of the Chosŏn Film Decree in January of 1940. (It would go into effect in August of that year.)
The 1940 Chosŏn Film Decree (henceforth, CFD) was closely modeled on the Film Decree passed in the Japanese Imperial Diet in 1939, which, in turn, took its cues from the Nazi Party’s film laws legislated in 1934. Of the many regulatory measures, the most notable were as follows:
- Permit requirement for film production and distribution
Unlike previous regulations, which had involved the censorship of the final product, the CFD began to exercise direct control over the film industry’s business, providing the foundation for the later mergings of the production and distribution companies. The permit system demanded production companies provide detailed information about their business, in terms of location, equipment, property, as well as descriptions of the films produced (genre, number of films, staff).
- Filmmaker registration
Along with a detailed survey of film businesses, the GGK also required personnel involved in film production to register themselves officially, providing detailed personal information such as address, date of birth, and type of occupation; this registration (which appears to have functioned like a license) could then be summarily suspended or revoked at the discretion of the GGK.
An article in the first issue of Eiga Junpo in January 1941 reports that the registration of film production personnel was conducted through an evaluation process conducted by a qualification committee, comprised of members of the censorship board, the GGK, academics, and members of the Chosŏn Film Artists Association (朝鮮映畵人協會); the article stated that personnel with prior film production experience were qualified on the basis of their papers, while others were to be further evaluated at a later date.
- Notification of film project before production
The CFD stipulated that filmmakers must report their film (title, content, scriptwriters, director, actors, filming schedule) to the GGK before filming began, as well as providing any additional notifications about changes that occurred during production.
- Limitations on importation and distribution of foreign films
Film distributors were not permitted to distribute foreign fiction films beyond the quota stipulated by the Governor-General of Korea, and were required to submit request forms for which foreign films they would be distributing. (Cho Chunhyŏng writes that, while restrictions on foreign film importation already existed, the main concern here seems to have been the possibility of ideological influence, rather than protection of the domestic film market.)
- Pre-release censorship
An entirely separate process of submitting the film for examination and censorship was required post-production. The principles of censorship closely mirrored those of the Japanese Film Decree, banning films that may ‘profane the emperor,’ ‘politically, militarily, educationally, diplomatically, or economically harm the interests of the empire,’ have a corrupting influence on the populace, etc. An addition specific to the CFD that was not in the Japanese version was a ban on films that could ‘cause hindrance in the governance of Chosŏn.’
- Required screenings of policy films
Cho Chun-hyŏng points out here the increased interest in Japan for wartime footage (and, indeed, the effectiveness of such films) during the Sino-Japanese War as a key factor for the greater emphasis on culture and news films, but Markus Nornes points out that non-fiction cinema played an important supplementary role to newspapers in Japan as early as the 1900s, when film crews were sent to document the Russo-Japanese War. He argues that ‘films wielded uncommon power for audiences excited by newspaper accounts,’ and how these films were effective in ‘[soliciting] identification with this national project across the Sea of Japan.’ In the imperial government’s transition to a wartime regime, undoubtedly films’ effectiveness in shaping national subjects was recognized and therefore films were aggressively utilized for ‘national education.’ According to the CFD, film theaters were required to screen ‘over 250 meters of [government approved non-fiction] films’ per screening.
Besides the exhaustive and arduous requirements detailed in the CFD – which added an onerous burden onto an already beleaguered film industry – Japan’s comprehensive transition into a wartime regime also meant that ration regulations were applied to the supply of raw (unexposed) film, which was classified as military equipment. Raw film rationing (Seng Pillŭm Paegŭpje), which was carried out in both Japan and Chosŏn, became an important bargaining chip with which the imperial government was able exercise control over film production. Chosŏn filmmakers were required to file requests with the GGK for 2-3 months’ worth of raw film, after which the film would be provided by the Ministry of Colonial Affairs through the Intelligence Bureau. Soon, however, it became clear that there would not be enough raw film made available for non-government film production, and finally in August of 1941, the Cabinet announced that they could no longer provide military equipment for civilian use. In both Japan and Korea, raw film rationing became an important means through which the imperial government was able to shape the industry by coercing numerous film companies into merging and nationalizing.
Government and Film Organization Relations in Nationalization of the Film Industry
The nationalization of the entire Chosŏn film industry, however, was notably only conducted in the colony, whereas the Japanese film production companies were rounded up and merged into the three largest companies: Toho, Shochiku, and Daiei. In Chosŏn – where the film industry was much smaller, with fewer companies of significant size – all production companies were forcibly merged and incorporated into the Chosŏn Film Production Corporation (朝鮮映畵制作株式會社). Likewise, distribution was also unified (again, unlike in Japan) and administered solely by the Chosŏn Film Distribution Company (朝鮮映畵配給社). Kim Yŏ-sil writes that, in actuality, both the Production and Distribution Companies were likely managed by the Governor General directly as ‘policy companies (kukch’aek hoesa),’ and indeed, a review of the Chosŏn Film Production Corporation’s second film Portrait of Youth in the film magazine Shin Eiga supports this characterization: ‘In a day such as today when all film production must be pertinent to policy, the identity of [Chosŏn Film Production Corporation] – currently the sole film production company in Chosŏn – must be seen as an excellent policy company.’
The creation of the Chosŏn Film Production Corporation (henceforth CFPC – in Korean the company is commonly referred to as ‘Choyŏng’), however, was not a speedy affair, nor was it exclusively government-directed. The process of executing the measures delineated by the CFD – as well as further measures such as raw film rationing – was very much conducted through or in co-operation with various film-related organizations that were formed around this time, such as the aforementioned Chosŏn Film Artists’ Association, which was headed by Koryo Film Association’s Lee Ch’ang-yong. Industry nationalization was first set in motion with the formation of the Chosŏn Film Producers’ Association (朝鮮映畵製作者協會), formed in October of 1940. (Other secondary literatures list it as December of 1940, but without primary source citation, so I have decided to follow the dates I have found in primary sources.) Ten film production companies were counted as members of the Producers’ Association at the time of its formation, most notably Chosŏn Film Corporation (represented by Choi Namju), Myŏngbo Film Company (rep. film director Lee Byŏng-il) and Koryo Film Association (rep. Lee Ch’ang-yong, Japanese name Hirokawa Soyo).
This association – much like other similar organizations – was formed on the basis of mutual goals on the part of Korean film producers and the GGK in terms of finding common ground in following the stipulations of the CFD. As such, it appears to have been an active entity in the execution of some of the terms of the CFD and its following provisions, including the prohibition of the sale of raw film to production companies who were not members of the association, delimiting the status of production company as only those with production equipment, etc. The association met with the Governor General’s censorship board in September of 1941, which resulted in the formal creation of a unified CFPC, which explicitly stated as its purpose the ‘production of national policy films’ as necessitated by wartime demands. The company formally received a permit for operations on September 2nd, 1942, and was registered as a company on the 29th of that month. 
While the merging of the companies was a somewhat prolonged process – partly due to the difficulty of evaluating the value of all these companies – the practical dimensions of merging may not have been as complex, due to the fact that there only a few companies owned proper filming equipment and film sets, which were then rented out for use by other companies. In a July 1941 survey by Eiga Junpo, the Chosŏn Film Corporation (朝鮮映畵株式會士, the aforementioned company represented by Choi Nam-ju, not to be confused with the unified government entity CFPC) lists the Kyŏngsŏng Ilbo Company, Myŏngbo Film Company, and the Hanyang Film Company as regular clients of its film set.
Kim Yŏ-sil notes that, while some filmmakers such as Yun Pong-ch’un and Lee Kyu-hwan directly resisted or rejected the New Film Order, many filmmakers and film production personnel were receptive to it, viewing it as a positive step for the Chosŏn film industry. Director Lee Byŏng-il of Myŏngbo Film Company produced Spring on the Peninsula (Pando ŭi Pom), which reflected an optimistic view of the New Film Order and the opportunities that it could bring. Moreover, various articles and reports in Japanese film magazines contain conversations with film workers that reflect a hunger for the industry’s growth and success. Film producer Lee Ch’ang-yong, in a 1939 roundtable discussion with Japanese film experts, argued (in a discussion about the failure of the Korean-Japanese co-production film Military Train): ‘But [Chosŏn filmmakers] have passion and talent. If a more proper producer or leader were to appear and systematically conduct operations, I am certain that better films can be made than now.’ Film production worker (and later, influential film producer) Lee Chae-myŏng, listed as ‘head of production’ at the Chosŏn Film Company’s Ŭijŏngbu film set in the Eiga Junpo survey of 1941, is mentioned by film critic/writer Uchida Kimio in his visit to the Ŭijŏngbu set in 1939.
‘The film set had one stage and a sound recording studio completed, but was otherwise still under construction. But Lee Chae-myŏng said that a new production would begin filming in the near future. There was a sense of motivation that Chosŏn film would begin here, that it would truly be reborn from now.
At half-past six there was a roundtable discussion with members of the Chosŏn Film Artist Association at the Nagayasu building, so I attended it with Hazumi kun and Matsuda kun. Those present were producers Lee Ch’ang-yong and Lee Chae-myŏng, film directors Pang Han-jun, Sŏ Kwang-je, Kim Yu-yŏng. … The topic at hand was how to develop Chosŏn cinema; the attendees were enthusiastic in their discussion and asked us astute questions.’
The somewhat rose-tinted tone of the account aside, it is clear that the problem of the Chosŏn cinema’s lackluster performance in terms of production quality and box office success was a pressing one for those in the industry. The general dearth of funding sources, the scarcity of technological equipment, and the lack of personnel who could operate the equipment were all persistent problems in Chosŏn filmmaking, problems that could find (a temporary) resolution by co-operating with the GGK’s demands and working for the CFPC. Cho Chun-hyŏng writes that the uncomfortable truth that ‘the filmmakers who actively or passively collaborated with the Japanese through the CFPC in the late 1930s and 1940s later became the backbone of post-1945 and post-Korean War Korean Cinema’ has led to a neglect of scholarship in this time period. And indeed, as I will go on to demonstrate in later on, the continued presence of these collaborating figures in the Korean film industry would contribute to the appropriation of the CFD in the 1962 Motion Picture Law, its subsequent amendments, and the implementation of these measures.
- 1945-1950, 1953-1961: Inter-war and Post-war Periods
As the focus of this paper is a comparison of the 1940 CFD and the 1962 Motion Picture Law, I will not be devoting a great deal of time to the inter-war and post-war periods, but at the same time, it is important to address them as periods of continuity and break in terms of film production and policy. Kim Mi-hyŏn – whose periodization I have adopted here in defining the ‘Liberation Period’ as 1945 to 1950 – points to the proliferation of films depicting independence fighters, liberation, and new nation construction immediately following 1945, despite the fact that, ‘following the end of the war, the Japanese left with all the film and equipment, leaving Chosŏn cinema to begin again in the rubble.’ In the few years leading up to the Korean War, as the North-South division was increasingly concretized and the ideological antagonism was exacerbated, films concerning anti-Communist sentiment and the tragedy of national division were released. Ironically, many of these liberation-era films were directed former members of the Chosŏn Film Artists Association (Hong Kae-myŏng, An Chong-hwa, Choi In-kyu, An Ch’ŏl-yŏng, etc).
Film organizations at this time also saw a great deal of irony in that ideological leanings appeared to become meaningless in their formation. The Chosŏn Film Construction Headquarters (Chosŏn Yŏnghwa Kŏnsŏl Ponbu – colloquially shortened to ‘Yŏng’gŏn) was formed on August 19th, 1945, electing Lee Chae-myŏng as the central chairman. Meanwhile the Chosŏn-era leftist artists’ organization KAPF (Korea Artista Proleta Federacio) appeared to have a revival in the Chosŏn Proletariat Film Alliance (Chosŏn P’uroletaria Yŏnghwa Tongmeng – colloquially P’uro Yŏngmeng) that formed the following November, primarily organized by previous KAPF members Kang Ho and Na Ung. Though P’uro Yŏngmeng initially had a more explicit ideological direction in that it was formed expressly for ‘proletariat film,’ it eventually merged with Yŏng’gŏn under the slogan of ‘Anti-Imperialist, Anti-Feudal, Anti-Chauvinist, Democratic National Cinema’ that December, to form the Chosŏn Film Alliance (Chosŏn Yŏnghwa Tongmeng). Though considered from the outset to be left-leaning, the Alliance saw members from Yŏng’gŏn who were considered right-leaning (Lee Byŏng-il, Choi In-kyu, Lee Chae-myŏng, etc) mix freely with left-wing artists such as Ch’u Min and Sŏ Kwang-je.
Before its eventual collapse in 1947 – secretary and leader Ch’u Min defected to the North in 1946, and Sŏ (who led the Seoul branch of the Alliance) is presumed to have done the same in 1947, contributing to an ultimate suspension of the group’s activities by 1947 – the CFA conducted striking protests and left numerous writings sharply criticizing the US military film policy in Korea. Two main issues defined the CFA’s protest activities, and indeed were key elements of the US military government’s film policy in Korea up to 1950: the existence of the Central Motion Picture Exchange (CMPE), and the film censorship regulations promulgated in April 1946.
CMPE-Korea, a US distribution company which owned exclusive rights to distribute films by companies such as MGM and Warner Brothers, flooded the Korean film market with US films, which greatly concerned filmmakers. Moreover, it also collected 50% of all box-office revenue from exhibitors, which was an arrangement even more uneven than in the colonial era. Added to that, the military government legislated film regulation and censorship to fall under the jurisdiction of the Ministry of Public Information (Kongbobu), a structure that was inherited by the Syngman Rhee government in 1948. Film regulations at this time stipulated that all films be submitted for pre-examination by the Ministry before exhibition, and films that failed to do so would be confiscated. Cho Hye-jŏng notes that, though regulations were announced in April, the military government was already censoring and confiscating Soviet-produced films in March, tensions with the Soviet Union already heightening on the peninsula; for Korean filmmakers, who ‘believed that the US was a nation that worshipped freedom and democracy,’ these acts of censorship came across as a massive shock.
The regulation of film by the Bureau of Public Information became a source of intra-government conflict in the Rhee government, as the Kongbobu frequently locked horns with the Ministry of Culture and Education (Munkyobu), which laid claim to the authority to censor productions and permit public performances. The conflict was ultimately resolved in 1955, when the Munkyobu was officially recognized as the central acting body for film regulation – a shift that reflected the government’s drive to use education and cultural policy to reconstruct society, form national subjects, and unify the populace. This approach does not at first glance appear entirely different from American and Japanese attitudes, in that film was still understood to be manipulative device and channel for government control over the population, but the Rhee government’s institution of new film policies starting in in the mid-1950s also gesture to a concern for the film industry, and efforts to protect and cultivate it. Lee U-sŏk notes that it is around this time when ideas and goals such as ‘corporatization’ and ‘entry into international film festivals’ first began to take root.
Of the Rhee government’s policies, the most notable were: tax exemption for domestic film tickets (which effectively knocked off 60% of the ticket price) and reward systems for domestic film production and exportation (companies were awarded with foreign film importation rights). Lee points out that these policies simultaneously resulted in the quantitative growth of the film industry, but also gave rise to the issue of corporatization – that is, the need for a systematized, stable development model for film companies, which all too often were wont to produce one hit film and then go under. The Rhee government policies, though they were not all adopted and continued in the Park government, laid part of the groundwork for key elements in the 1962 Motion Picture Law, as well as shaping key concerns within the film industry that would resonate into the 1960s.
- 1961-1979: The Park Chung-hee Era’s Motion Picture Law (Yŏnghwapop) and its Revisions
Lee U-Sŏk asserts in his introduction of inter-war and post-war film regulations that ‘many film policies legislated and implemented during the US military government and the Rhee Syngman-era continue to have influence today,’ and indeed, as he points out, the persistent issues of corporatization and film festival participation were raised in this interim period. Yet I would also suggest that, in viewing only direct temporal continuities and discontinuities in the history of Korean film policy, we neglect the longer-range resonances that can be found non-tangential (but still fairly proximate) time periods, such as the affinities between the colonial era and the Park era. In particular, Lee’s approach does not seem to fully incorporate the fact that many of the filmmakers, producers, and film personnel in action during the Park era had begun and shaped their careers during the colonial era.
In this section, I will examine the 1962 Motion Picture Law instituted by the Park regime following Park Chung-hee’s coup, as well as the four revisions that were made during his 19-year presidency. (Two more revisions were made in the years following Park’s assassination, but for the purposes of this paper I will not be discussing the 1985 and 1987 revisions.) In analyzing the key elements that constitute the original 1962 Motion Picture Law and its revisions, I will demonstrate that the Park government’s film policies appropriated features from the 1940 CFD just as much as it inherited ideas from the US military government and the Rhee government; these features were then implemented as necessitated by market demands and political conditions of the time. Moreover, even outside of elements of the Motion Picture Law that directly correspond to elements of the Chosŏn Film Decree, we can still find plenty of affinities between the ways in which the Park regime and the Governor-General of Korea attempted to shape and direct the film industry’s activities.
Key Characteristics of the Park-Era Film Policy
The initial Motion Picture Law was instituted a little over half a year after Park’s coup, in the January of 1962, the first comprehensive work of legislation concerning film administration since the 1940 CFD. (It is important to also note here that the Motion Picture Law was accompanied that year by a constitutional amendment that would officially allow censorship of film and public exhibition, which would go on to be the basis for the Motion Picture Law’s revisions.) One of the most striking characteristics of the various measures delineated is that the responsibility of film censorship and regulation once again was returned to the Ministry of Public Information, with the main decision-making body in most cases being the Public Information Minister (Kongbobu Changgwan). The Ministry of Culture and Education appears to have conducted the preparatory measures for the Motion Picture Law’s enactment, and continued to oversee film-related issues outside of censorship, such as supporting South Korea’s hosting of the Ninth Asia Film Festival in 1962. The basic structure laid out by the 1962 Motion Picture Law dictated that the Public Information Ministry would oversee the following:
- Film producers, importers and exporters must be registered at the Ministry of Public Information
- Film producers must report film projects before production begins to the Minister of Public Information.
- Film importers must be recommended by the Public Information Minister to import foreign films.
- Exhibitors of films must receive a license from the Public Information Minister
- The Public Information Minister is authorized to revoke exhibition license for reasons such as fraud, violation of license regulations, and other infringements on the Motion Picture Law’s regulations.
- The Public Information Minister is authorized to suspend or interrupt a film’s exhibition, if there are concerns that the film may offend public decency, or other reasons.
This initial configuration of film industry regulations, and the Park regimes actions in laying groundwork for the implementation of the law, provided the guiding principles for how the Park regime would continue to address the issue of control over film production, film content, and film importation. But even before the Motion Picture Law went into effect, the Park regime – in a manner not unlike the Japanese imperial government’s rounding up of Japanese film companies into three major ones in the late 1930s – grouped together film producers who had less than fifteen film works under their belt and made them register as film production companies together, ‘tidying’ seventy-two film companies of various sizes into sixteen by the end of 1961. This was a measure for both efficient control and corporatization, in that fewer film companies were easier to manage and regulate, but also it addressed the issue of sham companies that would produce a single film and go bankrupt. By the end of this preliminary round of merging – which Park Ji-yŏn describes as preparatory measures for the implementation of the Motion Picture Law – only Shin Sang-ok’s Shin Film was able to register as a company on its own.
The Motion Picture Law’s filmmaker registration system can be seen as a kind of exercise in both close control of industry production and strategic stimulation of film sector growth. While the Motion Picture Law’s initial form did not specify pre-requisites for company registration, the First Revision that was made the following year (1963) created a system that presented the industry with definitive standards and outlines, cutting away the ‘dross’ of the industry by imposing requirements for production company status, and closely cataloguing the companies that did qualify. The First Revision demanded that film production companies be equipped with the following (before they registered at the Ministry of Public Information): ‘filming equipment of at least 35 mm, lighting equipment, studio of at least 200 pyŏng (approx. 7117 square feet), recording equipment, and exclusively employed film directors, actors, and technicians.’
This material and technological standardization of film production hearkens back to the filmmaker registration process of the 1940 CFD, which also involved a survey of technician personnel and their levels/areas of expertise before they could legally register to ‘practice’ filmmaking; the qualification process under the CFD also gave priority to prior filmmaking experience, just as the Park regime decreed that film production companies needed at least fifteen works to their name. In the First Revision, the stipulation that companies must produce at least fifteen films per year was also added, though this soon proved too onerous for companies to keep up with (even for the mighty Shin Film, eventually). The economic and technological standards required for companies to maintain were adjusted with each Revision in subsequent years, usually corresponding to filmmakers’ complaints and concerns that the domestic film industry would collapse.
These industry-level regulations on film company activity would reach a head in the Fourth Revision of 1973, commonly dubbed the ‘Yushin Motion Picture Law’ as it was enacted following the declaration of Yushin in October 1972, and – like the Yushin regime – entailed intensive and harsh regulatory measures for the film industry, measures that I find are the most reminiscent of the CFD. The Fourth Revision involved the creation of a government-sponsored company for the production of national policy films, the transition from a film production registration system to a film production permit system (and the revival of strict technological and financial requirements for production corporation status), and the establishment of a Distribution Association (Paegŭp Hyŏphoe) to better address problems in film distribution. In accordance with the general mode of governance in the Yushin era, the Yushin Motion Picture Law also enacted an aggressively government-centered, ideologically severe set of regulations that effectively made it impossible for independent filmmakers to create films, or for new film companies to enter the market.
Aside from the maneuver of registering and licensing filmmakers and film workers to produce cinema, the biggest and perhaps most definitive ‘bargaining chip’ that the Park government utilized was the rights for importations of foreign films. It is difficult to overstate the massive importance that the foreign film importation business had in the Korean film industry, not only in terms of how the government used importation rights as leverage to attempt to institute models of domestic film production growth, but also in terms of how the profitability of foreign film importation shaped the nature and content of domestic films throughout the 1960s and 70s. Indeed, if for the Japanese imperial government and the Governor-General of Korea their main ‘carrot’ in guiding the film industry toward specific directions was the raw film rationing system, for the Park regime it was foreign film importation rights (which manifested itself as the screen quota policy). But unlike the Governor-General, which used raw film rationing to nationalize Chosŏn film production and put it to use toward pro-empire, military recruitment cinema, the Park regime’s goals was to strategically stimulate growth in the film industry (though, much like the regime’s approach in other industrial and economic sectors, these strategies did not play out as planned).
The Park regime’s ‘experimentation’ with importation rights began with the First Revision in 1963, when the government attempted to assimilate the film production business with importation business; that is, by decreeing that companies that imported foreign films must also produce domestic films, it attempted to funnel some part of the profits from foreign film imports to domestic film production. Though theoretically a plausible-sounding plan, this attempt in the First Revision did not take into account that foreign film importation also required a certain amount of expertise, something that domestic film production companies did not necessarily have; as such, these film production companies, when they were awarded rights to import foreign films, promptly sold those rights at exorbitant prices to ‘professional’ import companies.
With the institution of these stringent requirements, film importation rights became extremely valuable, and led to the proliferation of literary films, enlightenment films, and anti-Communist films through the 1960s. Through these films, which would be recognized by the government as ‘excellent films (usu yŏnghwa)’ based on their ideological content more than their quality, film production companies could be awarded rights to foreign film importation rights. Kim Mi-hyŏn writes that, through cinematic adaptations of literary works, films attempted to ‘lean on the authority of literature to obtain accreditation of its “excellence”.’ While we of course cannot summarily dismiss 1960s Korean cinema as cinema created for the sake of foreign film imports, it is clear that the Park regime’s policies regarding importation rights ironically had a direct hand in shaping the domestic film production landscape, and moreover exacerbated the tendency to value or prize foreign films over domestic.
Government and Film Organization Relations in Film Industry Regulation
An editorial by film director Lee Byŏng-il in 1962 – after the institution of the Motion Picture Law but before the First Revision – is notable in that it specifically points out some of the issues that the Motion Picture Law attempted to address. ‘The Korean film industry, which still does not have a sturdy corporatized system (kiŏp ch’eje), suffers from a lack of equipment and a dearth of production capital, which prevent it from fully demonstrating its overflowing passion.’ Lee goes on to beseech for greater government attention and aid in the cultivation of the Korean film industry in this moment of ‘dynamic opportunity for change’ (‘hwoekkijŏgin chŏnhwan kihoe’); he mentions ideas such as the Film Fund (Yŏnghwa Kŭmgo), as well as pointing to the fact that ‘various first-world countries in America and Europe are enacting film laws to actively stimulate film industry growth in their respective countries.’
Not unlike colonial-era filmmakers such as Sŏ Kwang-je and Lee Ch’angyong before him, Lee saw the advent of the Motion Picture Law as a moment of opportunity to establish measures that would genuinely bolster and support the industry, not only in terms of domestic market success but also the potential for Korean film to be an export product. For Lee, the naming of Korea as the host of the Ninth Asia Film Festival in 1961 (owed, in part, to the fact that Korean films had been well-received at the Eighth Festival, with actors Kim Sŭng-ho and An Sŏng-ki being awarded best actor prizes), and its coincidence with the enactment of the Motion Picture Law the following year, may indeed have presented itself as an important turnaround moment for Korean cinema.
It is not only mere similarities in language and optimism that link the 1940 CFD and the 1962 Motion Picture Law, however. It is even more important to take note of the fact that the process of ‘rounding up’ and merging film companies was, once again, in close co-operation with film organizations, most prominently the (extremely familiarly-named) Korean Film Producers’ Association (Hanguk Yŏnghwa Chejakja Hyŏphoe, colloquially ‘Chehyŏp’), headed by none other than Lee Chae-myŏng. The Association, which was formed in June of 1955 (but rarely mentioned in secondary literature on Korean film history), elected Lee as the director in 1956, and also counted Lee Byŏng-il as one of its board members by the 1960s; as Lee Byŏng-il was named director of the Ninth Asia Film Festival, the Film Producers’ Association was also heavily involved in the Festival’s organization and funding.
More importantly, however, the Film Producers’ Association was an instrumental organization in the pre-Motion Picture Law round-up of small film production companies, much like the role of the Chosŏn Film Producers’ Association in the nationalization of the Chosŏn film industry through the merging of the ten major film production companies. In a 1961 article in the Kyŏnghyang Shinmun, the Korean Film Producers’ Association (KFPA) and the Foreign Film Distribution Association (‘Oehwa Paegŭp Hyŏphoe’) were named as the two central organizations that took the lead in the Culture and Education Ministry’s directives to merge the minor companies into sixteen and seven larger corporations, respectively. Because the KFPA became the organization on which the Culture and Education Ministry relied to consolidate existing entities, film production companies that were not members of the KFPA would not have had any chance to register with the government even if they had met the requirements put forth by the Ministry. This cooperative, perhaps even negotiational, model between government unit and film organization is strongly reminiscent of the cooperation between the Chosŏn Film Producers’ Organization and the Governor-General’s censorship board in the creation of the CFPC in the early 1940s, not least because of the presence of Lee Chae-myŏng and Lee Byŏng-il in both instances. In the 1961 minor production merger announcements, Lee Chae-myŏng’s own Taehan Film Company (Taehan Yŏnghwasa) and Lee Byŏng-il’s Yŏna Film Corporation (Yŏna Yŏnghwa Kongsa) are listed among the sixteen final companies.
The KFPA would continue to be an important organization in the implementation of Park-era film policy throughout the 1960s. In 1965, the Ministry of Public Information enacted the ‘Domestic Film Production Rights Allocation System’ for the purposes of regulating suitable levels of supply and demand, decreeing that 150 films was the maximum limit for domestic film production (1965 saw 189 films produced). After the Second Motion Picture Law Revision of 1966, the responsibility of the enforcement of this allocation system was handed over to the KFPA, which distributed production rights exclusively to registered film companies within the limit of 150 films per year.
My paper only covers a small portion of the primary and secondary materials available for perusal regarding the colonial and Park eras; in particular, the new accessibility of Japanese-language magazine articles concerning Chosŏn cinema in the 1930s-1940s (through the efforts of the Korean Film Archives) opens up exciting new possibilities for research into Chosŏn filmmaking and its relationship with the Japanese mainland. Lee Chae-myŏng and Lee Byŏng-il are only two of the many Chosŏn filmmakers who were involved in the Governor-General’s naissen ittai project with Chosŏn national film; editorials and articles from major film magazines such as Eiga Junpo, Shin Eiga, and Nihon Eiga reveal many others, and more importantly, the documented conversations between Chosŏn film experts and Japanese film experts provide us with a valuable glimpse into the positionality that colonized filmmakers assumed in relation to Chosŏn, Japan, and their pursuit of filmmaking.
While many filmmakers, particularly leftist filmmakers, have been lost to us after 1950, countless left-wing artists having defected to or kidnapped by the North, not a few filmmakers stayed in the South and remained prolific artists. My paper, though it began as a comparative analysis of legislative measures that were enacted by oppressive governments on frail film industries – it is only recently that the Korean film industry has burgeoned to its current stature – also brings out the importance of unearthing and exploring continuities between time periods through individual trajectories. By following the enduring careers of two film industry figures, producer Lee Chae-myŏng and director Lee Byŏng-il, we are able to discover how similar situations of cooperation, negotiation, and coercion occurred in both the colonial and Park eras, and how aspirations and visions for a prosperous Korean film industry endured. To return to the original inspiration of this paper topic – Kim Mi-hyŏn’s claim that the Motion Picture Law was based on the Chosŏn Film Decree – it seems too simplistic to argue that the Motion Picture Law merely appropriated clauses and ideas, that the similarities are simply textual. Rather, the we ought to view the laws in contexts that shed light on how the government bodies and filmmakers of these two time periods were situated in comparable (though not identical) circumstances, which contributed to the resonances that exist between the two legislations and their implementation.
Cho Chun-hyŏng, ‘Yŏnghwa Kŏmyŏl Ch’egyehwa ŭi sijak: 5.16 ihu 1960 nyŏnde ch’o yŏnghwapŏp kwa yŏnghwa komyŏl,’ Saram kwa Kŭl Issue No. 43, November 2014. Republished at Research Institute of Korean Studies website. Web. <http://rikszine.korea.ac.kr/front/article/humanList.minyeon?selectArticle_id=531>
Cho, Hye-jŏng, ‘Mikun Chŏnggi Chosŏn Yŏnghwa Tongmeng Yŏngu,’ Yŏnghwa Yŏngu, Issue No. 13. December 1997. 153.
‘Chosŏnŭi kinŭng simsa,’ Eiga Junpo, Issue No. 1, 1st January 1941. 11. Reprinted in ed. Korean Film Archive Film History Institute, Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 3, Seoul: Han’guk Yŏngsang Charyowŏn, 2010. 15.
Chwa Sŭng-hŭi, Lee Tae-kyu, Hanguk yŏnghwa sanŏp kujo pyŏnhowa yŏnghwa sanŏp chŏngch’aek: sujikchŏk kyŏrhap ŭl chungsim ŭro, Seoul: Hanʼguk Kyŏngje Yŏnʼguwŏn, 2006.
Articles reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 2, Seoul: Han’guk Yŏngsang Charyowŏn, 2010:
- Toyoshi Okuro, ‘Chŏlmŭm ŭi Ch’osanghwa’, Shin Eiga, January 1944 Issue, 35-36. Reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 2. 323.
- ‘Chosŏn Yŏnghwa ŭi Hyŏnsang ŭl malhanda,’ Nihon Eiga, August 1st 1939. 120-127. Reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 2. 200.
- Uchida Kimio, ‘Kyŏngsŏng esŏŭi 5 il,’ Kinema Junpo, Issue No. 700, 1st December, 1939. 19. Reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 2. 169
Articles reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 3, Seoul: Han’guk Yŏngsang Charyowŏn, 2010:
- Aki Akira, ‘Chosŏn Yŏnghwaryŏng 1 chunyŏn hwoego’ Eiga Junpo, Issue No. 28, October 11th, 1941. 29-30. Reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 3, 77-79.
- ‘Ch’waryŏng, Nokŭm, Hyŏnsangso Ch’ongram,’ Eiga Junpo ‘Summer Special Edition’, Issue No. 18, 1st July 1941. Reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 3, 38-39
Kim Mi-hyŏn, Hanguk Yŏnghwa Chŏngch’aek kwa Sanŏp, Seoul: Communication Books, 2013
Kim Yŏ-sil, Tʻusa hanŭn cheguk tʻuyŏng hanŭn singminji: 1901-1945-yŏn ŭi Hanʼguk yŏnghwasa rŭl toejipta, Seoul: Samin, 2006
Ed. Kim Mi-hyŏn, Hanguk Yŏnghwasa, Seoul: Communication Books, 2006
Ed. Kim Tong-ho et al., Hanguk Yŏnghwa Chongch’aeksa, Paju: Nanam Ch’ulp’an, 2005
Nornes, Abé Markus, Japanese Documentary Film, the Meiji Era Through Hiroshima, Minneapolis: University of Minnesota Press, 2003.
Yecies, Brian, Shim, Ae-gyung, Korea’s Occupied Cinemas, 1893-1948: The Untold History of the Film Industry, New York: Routledge2012. 149.
Lee Byŏng-il, ‘Uri ŭi tangmyŏn kwaje: Che 9 hoe Asia yŏnghwaje rŭl maja,’ Donga Ilbo, 6th May, 1962.
‘Asea yŏnghwaje ŏttŏk’e ch’irŭl kŏt in’ga,’ Donga Ilbo, 30th July, 1961. 4.
‘“Chehyŏp” imwŏn kaesŏn’ Kyŏnghyang Shinmun, 21st June, 1956. 4.
‘Che 9 hoe yŏnghwaje nŭn Sŏulsŏ Asea yŏnghwaje sipilil p’yemak chikhu palp’yo,’ Kyŏnghyang Shinmun, 21st March, 1961. 4.
‘Chŏngri dwoel Yŏnghwaga,’ Donga Ilbo, 21st September, 1961. 4.
‘Naeoe yŏnghwasa t’onghap,’ Kyŏnghyang Shinmun, 29th October, 1961. 4.
‘Yŏnghwa chehyŏp imwŏn kaesŏn,’ Kyŏnghyang Shinmun, 13th April, 1956. 4.
‘Yŏnghwa chejakja hyŏphoe imwon kaesŏn,’ Kyŏnghyang Shinmun, 2nd August, 1956. 4.
 Kim Mi-hyŏn, Hanguk Yŏnghwa Chŏngch’aek kwa Sanŏp, Seoul: Communication Books, 2013. 8.
 Kim Yŏ-sil, Tʻusa hanŭn cheguk tʻuyŏng hanŭn singminji: 1901-1945-yŏn ŭi Hanʼguk yŏnghwasa rŭl toejipta, Seoul: Samin, 2006. 84-85.
 Ibid., 192. Kim Yŏ-sil points out that the term ‘New Film Order’ was an extension of the fascist ‘New Order Movement’ (shintaisei undō) of late 1930s Japan.
 Ibid., 187-188
 Kim Yŏ-sil, ‘Chosŏn Yŏnghwaryŏng ihu iljeŭi yŏnghwa tongjewa kongjak,’ in ed. Kim Mi-hyŏn, Hanguk Yŏnghwasa, Seoul: Communication Books, 2006. 92.
 Summarized from Cho Chun-hyŏng, ‘Ilje Kangjŏmgi Yŏnghwa Chŏngch’aek (1903-1945),’ in ed. Kim Tong-ho et al., Hanguk Yŏnghwa Chongch’aeksa, Paju: Nanam Ch’ulp’an, 2005. 87-92.
 An organization created in 1939, at the initiative of the GGK (‘Chosŏnŭi “Yŏnghwaryŏng”to tŭdiŏ kongpo,’ Kinema Junpo, Issue No. 696, 21st October 1939.8. Reprinted in ed. Korean Film Archive Film History Institute, Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 2, Seoul: Han’guk Yŏngsang Charyowŏn, 2010. 159), the Chosŏn Film Artists Association appears to have been a preparatory organization for the promulgation of the CFD, according to Cho Chun-hyŏng (in Hanguk Yŏnghwa Chongch’aeksa, 95).
 ‘Chosŏnŭi kinŭng simsa,’ Eiga Junpo, Issue No. 1, 1st January 1941. 11. Reprinted in ed. Korean Film Archive Film History Institute, Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 3, Seoul: Han’guk Yŏngsang Charyowŏn, 2010. 15.
 Cho, 91
 Nornes, Abé Markus, Japanese Documentary Film, the Meiji Era Through Hiroshima, Minneapolis: University of Minnesota Press, 2003. 4-5
 Ibid., 5
 Cho, 91
 Ibid., 93
 Ibid., 94
 Ibid., 93
 Kim Yŏ-sil, 189
 Kim Mi-hyŏn, 92
 Toyoshi Okuro, ‘Chŏlmŭm ŭi Ch’osanghwa’, Shin Eiga, January 1944 Issue, 35-36. Reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 2, 323
 Cho Chun-hyŏng quotes film historian Lee Yŏng-il in saying that film artists who were not affiliated with this government-patronized organization were not permitted to participate in production (Cho, 95)
 Aki Akira, ‘Chosŏn Yŏnghwaryŏng 1 chunyŏn hwoego’ Eiga Junpo, Issue No. 28, October 11th, 1941. 29-30. Reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 3, 77-79.
 Cho, 96
 Other members included Hanyang Film Company, Kyŏngsŏng Film Production, Chosŏn Ku’kwi Film Company, Chosŏn Yehŭng Company, Chosun Culture Film Association, and Kyŏngsŏng Sound Film Production. Of these, only Hanyang Film Company and Chosun Yehŭng Company were headed by Koreans; all others were run by Japanese businessmen.
 Aki, 79
 Cho, 97
 ‘Ch’waryŏng, Nokŭm, Hyŏnsangso Ch’ongram,’ Eiga Junpo ‘Summer Special Edition’, Issue No. 18, 1st July 1941. Reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 3, 38-39.
 Kim Yŏ-sil, 194
 ‘Chosŏn Yŏnghwa ŭi Hyŏnsang ŭl malhanda,’ Nihon Eiga, August 1st 1939. 120-127. Reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 2. 200.
 Lee Chae-myŏng is also later recorded as one of the few Chosŏn personnel in the Chosŏn Film Company (Chosŏn Yŏnghwasa), the entity created in 1944 when the Film Distribution Company absorbed the CFPC and reorganized operations to conduct both production and distribution to increase efficacy. Lee is listed as chief of technology. (‘Chosŏn Yŏnghwa’ Nihon Eiga, 13th May, 1944. 31. Reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 2. 242)
 Uchida Kimio, ‘Kyŏngsŏng esŏŭi 5 il,’ Kinema Junpo, Issue No. 700, 1st December, 1939. 19. Reprinted in Ilbonŏ chapchi ro pon Chosŏn yŏnghwa 2. 169
 Cho, 103
 Kim Mi-hyŏn, 105
 Kim Yŏ-sil, 146-147
 Kim Mi-hyŏn, 104-106
 Ibid., 113
 Ibid., 112-113
 Kim Yŏ-sil, in her critique of collaborationist filmmaking, labels Sŏ Kwang-je as not so much a leftist as an opportunist, who saw a chance open up in the nationalization of the Chosŏn film industry when he returned in a timely fashion from a year-long sojourn in Tokyo. (Kim, 146) Though the motivations and actions of chŏnhyang (轉向) leftists deserve further study in a different paper, I feel that it is worthwhile to keep her characterization in mind in understanding film artists and film organizations before and after 1945, rather than easily accepting classifications of leftist versus rightist.
 Cho, Hye-jŏng, ‘Mikun Chŏnggi Chosŏn Yŏnghwa Tongmeng Yŏngu,’ Yŏnghwa Yŏngu, Issue No. 13. December 1997. 153.
 Cho Hye-jŏng, 140
 Yecies, Brian, Shim, Ae-gyung, Korea’s Occupied Cinemas, 1893-1948: The Untold History of the Film Industry, New York: Routledge2012. 149.
 Cho Hye-jŏng, 143
 Ibid., 143
 Lee U-sŏk, ‘Kwangbok esŏ 1960 nyŏnkkajiŭi Yŏnghwa Chŏngch’aek,’ in Kim Tong-ho et al., 160
 Ibid., 161-162
 Ibid., 162
 Ibid., 163-170
 Ibid., 184
 Ibid., 109
 Cho Chun-hyŏng, ‘Yŏnghwa Kŏmyŏl Ch’egyehwa ŭi sijak: 5.16 ihu 1960 nyŏnde ch’o yŏnghwapŏp kwa yŏnghwa komyŏl,’ Saram kwa Kŭl Issue No. 43, November 2014. Republished at Research Institute of Korean Studies website. Web.
 Im Sang-hyŏk, ‘Yŏnghwa wa pyohyŏn ŭi chayu, Hanguk yŏnghwa simŭi chedoŭi pyŏnchŏn,’ in ed. Kim Mi-hyŏn, 99
 ‘Chŏngri dwoel Yŏnghwaga,’ Donga Ilbo, 21st September, 1961. 4.
 ‘Asea yŏnghwaje ŏttŏk’e ch’irŭl kŏt in’ga,’ Donga Ilbo, 30th July, 1961. 4.
 Summarized and consolidated from the following sources: Kim Mi-hyŏn’s Hanguk Yŏnghwa Chŏngch’aek kwa Sanŏp, 12-13. Chwa Sŭng-hŭi, Lee Tae-kyu, Hanguk yŏnghwa sanŏp kujo pyŏnhowa yŏnghwa sanŏp chŏngch’aek: sujikchŏk kyŏrhap ŭl chungsim ŭro, Seoul: Hanʼguk Kyŏngje Yŏnʼguwŏn, 2006, and Cho Chun-hyŏng’s chapter in Kim Tong-ho et al., cited above.
 Park Ji-yŏn, ‘Yŏnghwapŏp Chejŏng esŏ che 4 ch’a kaejŏnggi kkaji ŭi yŏnghwa chŏngch’aek (1961-1984),’ in Kim Tong-ho et al., 193
 Ibid., 194
 Ibid., 195
 Park Ji-yŏn, in Kim Tong-ho et al., 225-230
 Park Ji-yŏn, ‘Yushin sidae ŭi yŏnghwapŏp,’ in ed. Kim Mi-hyŏn, 224-225
 Park, Ji-yŏn, in Kim Tong-ho et al., 211-212
 Kim Mi-hyŏn, ‘Yŏnghwapŏp kwa sanŏp kujo,’ in ed. Kim Mi-hyŏn, 172
 Lee Byŏng-il, ‘Uri ŭi tangmyŏn kwaje: Che 9 hoe Asia yŏnghwaje rŭl maja,’ Donga Ilbo, 6th May, 1962. 4.
 ‘Che 9 hoe yŏnghwaje nŭn Sŏulsŏ Asea yŏnghwaje sipilil p’yemak chikhu palp’yo,’ Kyŏnghyang Shinmun, 21st March, 1961. 4.
 In later years, Lee Byŏng-il would also go on to be elected director of the Korean Film Producers’ Association.
 ‘Yŏnghwa chehyŏp imwŏn kaesŏn,’ Kyŏnghyang Shinmun, 13th April, 1956. 4.
 ‘Yŏnghwa chejakja hyŏphoe imwon kaesŏn,’ Kyŏnghyang Shinmun, 2nd August, 1956. 4.
 ‘“Chehyŏp” imwŏn kaesŏn’ Kyŏnghyang Shinmun, 21st June, 1956. 4.
 ‘Asea yŏnghwaje ŏttŏk’e ch’irŭl kŏt inga,’ Donga Ilbo, 30th July 1961. 4.
 ‘Naeoe yŏnghwasa t’onghap,’ Kyŏnghyang Shinmun, 29th October, 1961. 4.
 During the nationalization of the Chosŏn film industry, Lee Chae-myŏng was a high-level employee of the Chosŏn Film Corporation, while Lee Byŏng-il was the head of the Myŏngbo Film Company, both of which were member companies of the Chosŏn Film Producers’ Association.
 ‘Naeoe yŏnghwasa t’onghap,’ Kyŏnghyang Shinmun, 29th October, 1961. 4.
 Park Ji-yŏn, in Kim Tong-ho et al., 200