| ▲ | RobotToaster a day ago | |||||||
>You may have heard that certain other countries "don't have Fair Use". This is facially true because they aren't common-law countries The UK is a common law country and technically doesn't have fair use. We have "fair dealing" exceptions, but these are stricter in than American fair use. This is in part because the laws originated from EU legislation which is normally written to suit Napoleonic law countries... | ||||||||
| ▲ | pbhjpbhj a day ago | parent [-] | |||||||
I don't think Fair Dealing is strict because it derives from EU law - what makes you say that? UK copyright legislation largely started with the Statute of Anne in 1810 (or thereabouts). I'm not sure we can blame the EU! Much of what we have now derives from ratification of the Berne Convention in the early part of the 20th Century. Although TRIPS also impacts things. The most recent changes to the CDPA 1988 derive from WIPO treaty, IIRC, rather than from EU law itself. It has certainly felt like there has been undue influence of UK copyright from USA-based interests over the last few decades. | ||||||||
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