Re: Moral rights (Was: copyright expiration as a spur to creativity)

Tim Arnold-Moore <tja[_at_]mds.rmit.edu.au> wrote:
>
> The Europeans may have compromised with each other (mainly by forcing
> the UK to tow the line) but how have the Europeans compromised with the
> Anglo-Saxon tradition (UK, US or other) on the issue of copyright [I
> genuinely don't know]?

By enshrining the principle of mutuality (is that the correct term?) into the US Computer Software Protection Act and the US Semiconductor Chip Protection Act the EU was forced to adopt similar legislation which was not necessarily coherent with traditional copyright law. Well, you could also put the question the other way round: How have the US compromised with the EU? Anyway, I think the different approches are very interesting, but we should not get into temptation of judging the systems. Let us just learn from each other. I may be a litte provocative, but I won't go further.

Moritz Roettinger

Dr Moritz Roettinger LL.M.
European Commission, Brussels
Universities of Vienna and Saarbruecken
moritz.roettinger[_at_]dg23.cec.be Received on Thu Sep 03 1998 - 15:36:44 GMT