Joerg Schilling schilling@fokus.gmd.de schrieb/wrote:
From my understanding, all progressive (so probably all continental european) countries use a law definition derived from ideas of the french revolution while the UK is still using laws derived from the roman law.
While it is true that Continental authors' rights ared based on ideas from the French Revolution, UK laws have never been influenced much by Roman Law. On the contrary, the UK legal system is based on the Common Law, which is completly different from the Continental-European Civil Law systems (or ius civile), which were derieved from the Roman Law.
The Anglo-American copyright system stems from censorship laws; you had to get a licence from the monarch to publish books. This license often granted exclusive rights to copy that particular book.
Claus