[Upd-discuss] Question regarding European Copyright law and U.S. law

[Peter Eckersley]

The argument that copyright term extensions are necessary to achieve
"harmonization" of the term in different locations is fallacious, because
they don't actually achieve this result.  See this parliamentary submission by
Matt Rimmer, and especially its appendix:

http://www.aph.gov.au/Senate/committee/freetrade_ctte/submissions/sub183.pdf

It's true that US copyright owners did obtain extensions in the EU following
the enactment of the CTEA, due to reciprocity rules in the Berne convention.

On Thu, Dec 23, 2004 at 12:26:42PM -0500, Sigmascape1@cs.com wrote:
> Hi,
> 
> I was doing some research on copyright law in the U.S., and specifically, attempting to understand certain aspects of the law. While doing this, I ran into a lot of information regarding the 1998 Copyright Extension Act (The notorious Sonny Bono act). One issue kept coming up in my research... the extension was necessary to put us (the U.S.) in line with Europe's copyright laws. Can someone explain what this means? In what way(s) did it put us in line? Was it simply the length of the extension? Generally speaking, what are the differences between Europe's take on copyright laws vs. the U.S.?
> 
> I was under the impression that our fair use stipulations were the big difference.
> 
> Thanks,
> 
> MLF
> 
> www.sigmascape.com
> 
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-- 
Peter Eckersley
Department of Computer Science   &                  mailto:pde@cs.mu.oz.au 
IP Research Institute of Australia             http://www.cs.mu.oz.au/~pde
The University of Melbourne