On Mar 9, 2007, at 3:04 AM, IOhannes m zmoelnig wrote: > Hans-Christoph Steiner wrote: >>> will be major differences between the anglo-american and the >>> european >>> way. (and other ways too, but about these i know even less) >> >> I think that they are not as big as you'd guess because there are >> international treaties that are all about making these laws work in >> the same ways across borders. Copyright, patents, and trademarks act >> quite similarly in all countries that participate in these treaties >> (which is most). > > not quite true. > (i'd say it is an anglo-centristic viewpoint ;-)) > after all, in anglo-american space we have to deal with "copyright" > whereas in continental europe we still have the "urheberrecht" > which is > something really different.
The mechanisms is different, but the functions are largely the same. For example, "Fair Use" with copyright is determined more by court rulings in the U.S. while I think that Urheberrecht/droit d'auteur codifies it as the right to quote. As for GPL in the German courts, it has been tested, and the GPL was legal and enforced: http://gpl-violations.org/news/20060922-dlink-judgement_frankfurt.html .hc >>> >>> things are certainly better in CreativeCommons (among other things >>> because they are less u.s.-centric than the FSF). >> >> Hmm, that's debatable. They don't have a license without an >> attribution clause, it's not even an option. And the CC attribution >> clause is much worse than the BSD attribution clause ever was. > > yes i agree here. > i was just trying to say that the creative commons is much more > "court-proof" in different countries since it has been adapted to > really > fit within the legislature of these. > > the GPL never had anything but the u.s.-american copyright law in > mind, > which makes it not necesserarily fit for other countries. > i do not say that the GPL is bad or futile in europe, it is the > license > i use... > > > mfg.asdr > IOhannes ------------------------------------------------------------------------ ---- Man has survived hitherto because he was too ignorant to know how to realize his wishes. Now that he can realize them, he must either change them, or perish. -William Carlos Williams _______________________________________________ PD-list@iem.at mailing list UNSUBSCRIBE and account-management -> http://lists.puredata.info/listinfo/pd-list