Quote:
Originally Posted by RobertDDL
Sadly I'm not qualified to elaborate on this, but the concepts of copyright and Urheberrecht do differ!
|
The concepts are not. Only the implementation. Copyright doesn't mean that is applicable to US only, like Urheberrecht doesn't mean it's only applicable to Germany (BTW, the Urheberrecht in Switzerland differs from AT and DE). It's a term that started long time ago, in Berne, and this convention is the mother of all CP worldwide.
Now, how strict some states/countries will go, depends on their interests. For instance, up to 1923 US even did not recognize the copyright of non-US works (meaning the US companies were free to copy and use European works for free). And it lasted until 1980 (or was it 1990, I don't remember exactly, very recently anyway) when they adhered fully to Berne convention, more than 100 years after. Even within EU, the copyright directive leaves room for play to member states, so if one is strict enough may say that whatever-is-the-word-for-copyright in Slovenia is different from the british-term-copyright in UK.
In your example, the lawmakers were lobbied to death by media industry (printed books, movies, music - all of these were developed faster and earlier in the US than everywhere else) and part of the copyright concept was taken out from the author in favour of the publisher. because the intermediate layer makes all the money in these businesses.
The old concept of copyright involved that the
creator/author does it everything on his own. Writing the book, printing it, selling it. Writing the song, performing it (live), selling it. Writing a script, composing a score, filming a movie, playing it in his own cinemas. The publishers were initially only helpers, like one normal Joe S Public asks a technician to fix the sink in the kitchen. Like renting the recording studios together with manpower. When the publishers flexed their muscles, they managed to get more importance, and finally they now dictate what's happening. The authors live in a sweet slavery, they won't or cannot leave.
PS: do you know how much has invested the lobby to raise the ancillary rights duration from 50 to 95 years? A meagre 58.000$. Une fourth of what they may get from a single infringer, if one believes the FBI warning
.