On Mar 9, 2007, at 3:04 AM, IOhannes m zmoelnig wrote:
Hans-Christoph Steiner wrote:
will be major differences between the anglo-american and the
european way. (and other ways too, but about these i know even less)I think that they are not as big as you'd guess because there are international treaties that are all about making these laws work in the same ways across borders. Copyright, patents, and trademarks act quite similarly in all countries that participate in these treaties (which is most).
not quite true. (i'd say it is an anglo-centristic viewpoint ;-)) after all, in anglo-american space we have to deal with "copyright" whereas in continental europe we still have the "urheberrecht"
which is something really different.
The mechanisms is different, but the functions are largely the same.
For example, "Fair Use" with copyright is determined more by court
rulings in the U.S. while I think that Urheberrecht/droit d'auteur
codifies it as the right to quote.
As for GPL in the German courts, it has been tested, and the GPL was
legal and enforced:
http://gpl-violations.org/news/20060922-dlink-judgement_frankfurt.html
.hc
things are certainly better in CreativeCommons (among other things because they are less u.s.-centric than the FSF).
Hmm, that's debatable. They don't have a license without an attribution clause, it's not even an option. And the CC attribution clause is much worse than the BSD attribution clause ever was.
yes i agree here. i was just trying to say that the creative commons is much more "court-proof" in different countries since it has been adapted to
really fit within the legislature of these.the GPL never had anything but the u.s.-american copyright law in
mind, which makes it not necesserarily fit for other countries. i do not say that the GPL is bad or futile in europe, it is the
license i use...mfg.asdr IOhannes
Man has survived hitherto because he was too ignorant to know how to
realize his wishes. Now that he can realize them, he must either
change them, or perish. -William Carlos Williams