On 4/22/07, Birgitte SB <birgitte_sb(a)yahoo.com> wrote:
I understand this, but I am not sure what your point
is in relation to the previous messages. Are you
supporting the idea that moral rights are of the same
importance as the "insulting Turkisness" law and
should be ignored by claiming US juristiction?
I was mainly writing in response to the first sentence of yours,
"Moral rights are not some oddball local law, but well-recognized area
of international copyright law acknowledged in the Berne convention."
I agreed to a certain extent, but my observation was that the
implementation is left up to the various countries and it has been
implemented in dramatically different ways. The US, for example, has
limited implementation (probably going below what Berne sets out) but
France, on the other hand, has a very strong implementation (probably
going beyond what Berne sets out).
Yes, the concept is "well-recognized" internationally but aspects of
particular implementations are certainly not.
--
Stephen Bain
stephen.bain(a)gmail.com