[PD] Percolate

mik mprims at skynet.be
Mon Mar 12 05:13:31 CET 2007

Hans-Christoph Steiner schreef:
> 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

it probably is, as is the belgian, which i am mainly talking about, all 
eu members have the same regulations to adhere to, after all, but the 
german system seemed a bit more strict to me, at first glance. it's the 
inalienablity of certain rights which seems to make the difference 
(between the us and the rest). the question is: does the berne 
convention precede national law?

ssssssorry: way OT. that question is one ask myself. this is not the 
place to continue discussing about it.


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