To be pedantic, the French droit d'auteur is very similar to urheberrecht, so there are other countries with different systems. I think we are basically on the same page. For the average person there is basically no noticeable difference between these systems, it's really just a question of the legal mechanisms used rather than the effects.
.hc On Mar 11, 2007, at 3:29 PM, mik wrote: > yes, okay, urheberrecht seems to be a particular case, only applicable > in germany. but on the whole most national copyright laws are very > alike, since most countries have signed the convention of berne, and > have the concept of moral rights, ie rights which never can be > transferred. what you cite as the general rules of us copyright is the > basis of almost any copyright law. the moral rights issue, however, > seems not to be entirely resolved in the anglo-american parts of our > planet, but in theory these countries should also protect these > rights, > as they have signed the berne convention. > > pffff. > > :) > > m > > > marius schebella schreef: >> I don't think "copyright" is the same as urheberrecht. I would rather >> compare it to authorship. the copyright goes always to the >> "owner". for >> example, when you work for a big Pd company and your boss says, >> write a >> pd patch for that exhibition, than you would be the author, but since >> that would be considered a "work for hire", your boss would have the >> copyright. >> in europe this is slightly different, because as the author/ >> urheber you >> have some default rights on your work, which you maybe do not have in >> the US. >> some general rules about the us copyright: >> copyright protects creative output, (compositions, lyrics, >> expressions, >> also gestures, lighting.....) but not ideas or facts. the important >> thing is always sufficiant creativity. >> it protects the copyright holder against unauthorized reproduction, >> display, performance, or derivative works. (of course this is only >> the >> short version.) >> one speciality for example is the "joined work", when several people >> work as a group on an artwork and you cannot split up the whole >> thing, >> then everybody would have the right to grant rights, but not >> "exclusive >> rights", which can only be granted, when all participants of the >> group >> agree on that... >> anyway, the biggest discussions in the US at the moment are about >> "fair >> use". lat's talk about that another time. >> marius. >> >> mik wrote: >> >>> copyright is the english (language) equivalent of urheberrecht. >>> there's >>> no difference. >>> this is an area everybody typically has a strong opinion about. >>> sadly >>> this opinion is mostly based on severe misconceptions. >>> >>> >>> m >> >> >> _______________________________________________ >> PD-list@iem.at mailing list >> UNSUBSCRIBE and account-management -> http://lists.puredata.info/ >> listinfo/pd-list >> > > -- > > http://www.mprims.net > > _______________________________________________ > PD-list@iem.at mailing list > UNSUBSCRIBE and account-management -> http://lists.puredata.info/ > listinfo/pd-list ------------------------------------------------------------------------ ---- Looking at things from a more basic level, you can come up with a more direct solution... It may sound small in theory, but it in practice, it can change entire economies. - Amy Smith _______________________________________________ PD-list@iem.at mailing list UNSUBSCRIBE and account-management -> http://lists.puredata.info/listinfo/pd-list
