Foreword

Very often when I read discussions (or take part in such discussions) on copyright issues, where one of the parties in the discussion comes from an common law jurisdiction (such as USA) and the other hails from a civil code jurisdiction, there are often quite serious misunderstandings, and these can ultimately be traced to a general lack of knowledge about the differences between the Anglo-American copyright tradition and the droit d’autheur tradition. Unfortunately there are very few sources of information about copyright issues, as seen from the droit d’autheur perspective, on English available on the Internet. There are a huge number of web pages explaining the US version of a copyright scheme, and while those pages makes a good job in explaining the subject, a lot of the information given in is misleading in an droit d’autheur context. This FAQ has the ambition to change that and become a source of information about copyright as is known in continental Europe and elsewhere.

In order to emphasise that several of the key concepts related to a copyright are somewhat different in the droit d’autheur tradition I will only use the term copyright when discussing Anglo-American copyright law. When talking about a copyright in the droit d’autheur sense I will either use the words author’s right, originator’s right or droit d’autheur.

Finally I must remind the reader that this site does not offer any legal advice, its purpose is to explain and discuss legal concepts. If you need legal advice, please contact a legal professional.