To be pedantic, the French droit d'auteur is very similar to
urheberrecht, so there are other countries with different systems. I
think we are basically on the same page. For the average person
there is basically no noticeable difference between these systems,
it's really just a question of the legal mechanisms used rather than
the effects.
.hc
On Mar 11, 2007, at 3:29 PM, mik wrote:
yes, okay, urheberrecht seems to be a particular case, only applicable in germany. but on the whole most national copyright laws are very alike, since most countries have signed the convention of berne, and have the concept of moral rights, ie rights which never can be transferred. what you cite as the general rules of us copyright is the basis of almost any copyright law. the moral rights issue, however, seems not to be entirely resolved in the anglo-american parts of our planet, but in theory these countries should also protect these
rights, as they have signed the berne convention.pffff.
:)
m
marius schebella schreef:
I don't think "copyright" is the same as urheberrecht. I would rather compare it to authorship. the copyright goes always to the
"owner". for example, when you work for a big Pd company and your boss says,
write a pd patch for that exhibition, than you would be the author, but since that would be considered a "work for hire", your boss would have the copyright. in europe this is slightly different, because as the author/ urheber you have some default rights on your work, which you maybe do not have in the US. some general rules about the us copyright: copyright protects creative output, (compositions, lyrics,
expressions, also gestures, lighting.....) but not ideas or facts. the important thing is always sufficiant creativity. it protects the copyright holder against unauthorized reproduction, display, performance, or derivative works. (of course this is only
the short version.) one speciality for example is the "joined work", when several people work as a group on an artwork and you cannot split up the whole
thing, then everybody would have the right to grant rights, but not
"exclusive rights", which can only be granted, when all participants of the
group agree on that... anyway, the biggest discussions in the US at the moment are about
"fair use". lat's talk about that another time. marius.mik wrote:
copyright is the english (language) equivalent of urheberrecht.
there's no difference. this is an area everybody typically has a strong opinion about.
sadly this opinion is mostly based on severe misconceptions.m
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