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You seem to be mistaken in assuming that US copyright law (or more precisely the decision set down in Bridgeman Art Library v. Corel Corp.) somehow applies to the world and not just the US.


Are you declaring that there are copyright doctrines more restrictive than the US? I'm very interested in hearing specifics!


> Are you declaring that there are copyright doctrines more restrictive than the US?

For copyright specifically (not IP in general, and definitely not patents), the US is very soft.

For instance many mainland euro country have a concept of Author's Rights (or moral rights), which may well be perpetual, inalienable, unwaivable and unassignable (in a company, the moral rights belong to the employee who created the work, the company has an exclusive license to the economy rights of the work). In french law, moral rights provide 4 sub-rights:

* divulgation right, the author is sole holder of the right to decide the original disclosure of the work

* paternity right, respect must be given to the parental relation between the author and the work

* work respect right, the author can forbid any and all transformative work. This alone means "fair use" is much, much broader in the US than in France

* repent right, even after divulgation the author can "uncirculate" the work (although he may have to compensate license holders)

and because these moral rights are perpetual and inalienable, you can't put something in the public domain in France, you can only provide a universal license. The work will only fall in the public domain once copyright has expired.


Lots of copyright doctrines are more restrictive than the US. Most notably, a lot of jurisdictions don't have a concept of fair use nearly as broad as the US concept.

Also, the US uses trade treaties to cajole other countries into adopting very restrictive copyright doctrines. It's more common than you'd think.


The lack of fair use is a problem in non-US jurisdictions.

However, I'm not aware of anywhere where copyright lasts longer than the US (except in special cases like Peter Pan[1], even if that is really just perpetual rights to royalties from performance[2]).

Edit: Just noticed that [2] says copyright in Mexico is actually longer than in the US, but I'm not aware of the specifics of how it works.

[1] http://www.jmbarrie.co.uk/copyright/

[2] http://www.gosh.org/gen/peterpan/copyright/faq/#Copyright


Honduras has life + 75 years. Also some countries provide circumstantial extensions e.g. France's copyright is life + 70, but if the author is "Mort pour la France" (died for France, which is usually applied to service members but may also apply to civilians) it's life + 80.


France also added a few years here and there. For example the period in WW2 when France was occupied by Nazi Germany doesn't count for copyright.


A few countries did that, but those extensions were mostly predicated on a 50 years copyright (the "morts pour la france" extension also is, it's 30 years tacked onto the original 50). When copyright got normalised to 70 by EU rules (or separately extended before EU or EU entry), these extensions became moot in EU countries. IIRC Russia is the only country where war copyright extensions still apply, as a 4 years extension was specifically added when they rewrote their copyright laws in 1993.


In this case what you're looking for is the "sweat of the brow" doctrine which holds that copyright is achievable through hard work and not just originality.

There are also entire classes of IP protection which the US doesn't recognise but are common elsewhere, for example sui generis rights.


Well, yes. Australia has no such thing as fair use, for a start.


"I'm very interested in hearing specifics!"

Sure you are. Just not interested enough to Google the specific case that was helpfully referenced in the comment you replied to.


That.. that is a US case.* I asked about places where there are stricter rules than the US, because I'm used to the US being the one pushing stronger copyright.

*And it was argued that the same result would have held in the UK.


Yes, the case is a US case. That's the point. It is a US case which has, in effect, granted people a degree of freedom not generally found elsewhere.

That is exactly what you asked for: a specific example of US law being more lenient than the law in other countries.




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