Copyright and Moral Rights in the U.S. and France
17 Pages Posted: 29 Jul 2011
Date Written: May 1, 2011
Abstract
The paper attempts to briefly outline some of the differences between French and American copyright law. The differences between the two copyright systems are partly a result of the differing philosophical underpinnings of the two systems. The natural law underpinnings of the French copyright system, for example, are manifest in the moral rights granted to authors. The American system is founded primarily on an economic philosophy, and accordingly does not include the granting of moral rights to authors. These different philosophies result in potentially significant differences in the ability of authors to license or assign their works to others. This paper will briefly discuss these and other issues, while comparing French and American copyright laws.
Keywords: united states copyright, france copyright, united states, france, french copyright, copyright, copyright law, moral rights, american copyright, american
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