[Foundation-l] Does "free content" exist in France?
saintonge at telus.net
Sun Apr 22 06:04:09 UTC 2007
Stephen Bain wrote:
>On 4/22/07, Birgitte SB <birgitte_sb at yahoo.com> wrote:
>>Moral rights are not some oddball local law, but
>>well-recognized area of international copyright law
>>acknowledged in the Berne convention. This is not at
>>all like "insulting Turkishness" were it is best to
>>just claim a different jusristiction and pretend it
>>doesn't exist. Not if you want to maintain any
>>integrity as an international movement anyways.
>The idea of moral rights is part of the Berne Convention, and the
>United States is unusual among signatories in not completely
>However the Convention leaves it completely up to the signatories to
>implement moral rights into their local law, and this has produced
>some wildly different results. French law is commonly held up as an
>extreme example but really the difference is between the civil law
>states (which love moral rights) and the common law states (which are
I've noticed this, and the divide seems to be more pronounced than in
the fair use problems. Although most legislation speaks of damages to
honour and reputation, I find it hard to see how some of the claims have
managed to establish this.
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