[Foundation-l] translation and the GFDL

[Ray Saintonge]

GerardM wrote:

>Hoi,
>
>On 7/6/07, geni <geniice at gmail.com> wrote:
>  
>
>>On 7/6/07, Ray Saintonge <saintonge at telus.net> wrote:
>>    
>>
>>>I'm not saying that CC will improve the situation.  Trying to adapt it
>>>to the laws of different countries could easily lead to more
>>>jurisdiction shopping.
>>>      
>>>
>>CC does that all the time.
>>    
>>
>You are wrong. What the CC does is write the notions of what a particular
>license is in language that is valid in that jurisdiction. This is distinct
>from what you find in GPL and GFDL where one size is to fit all. The idea is
>to be true to what the license expresses. The idea is that the license in
>essence is the same where ever.
>
The difficulty with CC3.0, of course, relates to moral rights.  As long 
as the jurisdiction for an alleged infringement were the place where the 
uploader lived the situation would be relatively easy.  If, however, the 
jurisdiction is, as some courts have determined, where the downloader 
lives there can be a lot of problems.  English common-law countries tend 
to have a more relaxed attitude toward moral rights.  It is 
problematical when a person in an English common-law country acts in a 
manner consistent with his country's laws suddenly finds himself charged 
under the more rigid French or Swedish law because a person in that 
country happened to download material that violated moral rights.  There 
is no extradition for copyright violations, but it could make a person's 
future travel plans difficult.

Ec