> So, if you're wondering what he means by "English Common Law", let me answer your confusion with another question: why doesn't Japan have Fair Use? “Fair Use

> So, if you're wondering what he means by "English Common Law", let me answer your confusion with another question: why doesn't Japan have Fair Use? “Fair Use” isn’t “English Common Law”, it is an American doctrine; most other common law jurisdictions - including England (and the rest of the UK), Australia, Bangladesh, Canada, India, Ireland, New Zealand, Pakistan, South Africa - have the narrower fair dealing doctrine instead. According to Wikipedia [0] the main countries other than the US with fair use are Malaysia, Poland and South Korea. Singapore has recently adopted a hybrid model combining elements of both fair use and fair dealing. > Well, the answer's simple: they can't, because judges aren't allowed to legislate from the bench over there. In civil law countries, the law is the law, full stop; judges can't add onto it in any meaningful way. This is nonsensical. Most common law countries don’t have fair use, they have the narrower fair dealing doctrine instead; but some civil law jurisdictions do have fair use, such as Poland and South Korea. Common vs civil law has no real bearing on fair use vs fair dealing vs neither - it is a policy choice legislators make when enacting statutory copyright law. [0] https://en.wikipedia.org/wiki/Fair_dealing#/media/File%3AFair_use_laws.png https://en.wikipedia.org/wiki/Fair_dealing#/media/File%3AFai...