Hans-Christoph Steiner schreef:
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
it probably is, as is the belgian, which i am mainly talking about, all eu members have the same regulations to adhere to, after all, but the german system seemed a bit more strict to me, at first glance. it's the inalienablity of certain rights which seems to make the difference (between the us and the rest). the question is: does the berne convention precede national law?
ssssssorry: way OT. that question is one ask myself. this is not the place to continue discussing about it.
m