[PD] Percolate

Hans-Christoph Steiner hans at eds.org
Mon Mar 12 04:48:06 CET 2007

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.


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
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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

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