From: Tor-Einar Jarnbjo (Tor-Einar@Jarnbjo.de)
Date: 09/22/03-05:22:14 AM Z
Hi,
there are actually substancial differences on copyright laws in different
countries and many countries does not have a copyright at all (most
European countries except UK and Ireland) but a droit d'auteur (author's
right). As I've understood it, the meaning of a copyright is slowly
(at least in US legislation) slowly drifting to become an author's
right too.
The difference is, that the copyright regulates the right to copy
(print) and publish a written work. In the USA, up to about 30 year
ago (I think the change was made in the 70s), this right had to be
registered to be effective and it was common that the copyright was
registered by the publisher and not by the author. It was also significant
for a copyright (it still is, as interpreted by WIPO) that a copyright
claim was expressed as in "© Copyright <year> by <copyright holder>".
The US copyright used to be limited to 28 years, it was extended
to 75 years and it will probably be extended again as Disney's copyright
on Mickey Mouse is about to expire.
On the other side, an author's right is implicit and does not have
to be claimed. It is usually intransferrable and extends throughout
the author's life and for some period after his death. It gives the
author a right to decide who is allowed to print, publish and distribute
his work and in some cases even withdraw an already delegated right.
But, it also regulates where his rights does not apply and in which
cases the author is not allowed to restrict use, reproduction and
distribution of his work.
Tor
Mandag, 22 september 2003, skrev du:
>Yup, this is all too sadly true here too :( Btw, I've studied copyright
law,
>albeit on a minor level, also had a tut on it just the other day
so I'm up
>to speed as far as N.Z. goes I think and there isn't much diffference
as far
>as I can tell.
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