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>> US copyright law only applies in the US This isn't entirely true, due to various entangled trade agreements that require countries to respect each other's i
by errantmind 4y ago
>> US copyright law only applies in the US
This isn't entirely true, due to various entangled trade agreements that require countries to respect each other's intellectual property as a prerequisite.
See
https://en.m.wikipedia.org/wiki/Berne_Convention https://en.m.wikipedia.org/wiki/Berne_Convention
- zarzavat 4y agoThey require countries to respect each other's copyrights, not each other's copyright law. The US, for example, does not enforce EU database rights. Moreover, you can in EU copy a book made by a US author who died 80 years ago even if that copyright is still valid in the US. Local laws are enforced by local courts. What the Berne Convention requires is that if I have a copyright in US it will be recognised in France, etc without having to re-register it in every country in the world. There is no part of the Berne convention that will prevent people from training models on US copyrighted works outside of the US. That is entirely a matter for local jurisdiction.
- kragen 4y agodatabase rights are not copyrights but a new sui generis monstrosity, but this comment is otherwise correct
- roywiggins 4y agoTrade agreements have been used to require other nations to extend their copyright terms to match the US, eg Canada: https://cassels.com/insights/copyright-term-extension-in-canada-will-come-into-force-december-30-2022/ https://cassels.com/insights/copyright-term-extension-in-can...
- BeFlatXIII 4y agoMore legislatures ought to repudiate the treaties their predecessors blindly signed.