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Yes, more or less, but they are generally not as generous as the US. E.g., the UK equivalent of fair use, "fair dealing", is limited to a definitive list of ci
by chalst 13y ago
Yes, more or less, but they are generally not as generous as the US.
E.g., the UK equivalent of fair use, "fair dealing", is limited to a definitive list of circumscribed purposes of the unauthorised use of copyright material, e.g., in writing a review. By contrast, US law has a non-exclusive set of tests to check if an unauthorised use is fair use, of which purpose is just one factor to be weighed in the balance.
I gather that Germany does not have any fair use law [1], but in practice a regime similar to the UK's has been established through several precedents in the German courts. France seems to be in a similar situation, with a more generous court interpretation of fair use [2].
Wikipedia tells me that Israel has a fair use law similar to the US; cf. [3].
[1]: http://moritzlaw.osu.edu/students/groups/is/files/2013/08/8-Potzlberger.pdf http://moritzlaw.osu.edu/students/groups/is/files/2013/08/8-... - note that vog's comment below seems to refute this source
[2]: https://cyberlaw.stanford.edu/blog/2011/01/who-said-france-does-not-have-fair-use https://cyberlaw.stanford.edu/blog/2011/01/who-said-france-d...
[3]: https://cyberlaw.stanford.edu/blog/2008/01/israel%E2%80%99s-fair-use https://cyberlaw.stanford.edu/blog/2008/01/israel%E2%80%99s-...
- vog 13y agoWhile Germany may not have an exact equivalent of "fair" use, it does have something similar, in the law. It is named "Schranken des Urheberrechts" (limitation of copyright law), which you can find in §§ 44a to 63a (e.g. [1] and [2]). Part of it is the famous (at least in Germany) "Privatkopie" (private copy) which allows for copying material for private use. [3] [1] http://dejure.org/gesetze/UrhG/44a.html http://dejure.org/gesetze/UrhG/44a.html [2] http://dejure.org/gesetze/UrhG/63a.html http://dejure.org/gesetze/UrhG/63a.html [3] However, you are not alloweed to break an effective copy protection on that way ... which is kind of contradictory, becase if lots of people manage to create those copies privately, that "copy protection" mechanism wasn't really "effective", was it?
- TomaszZielinski 13y agoIn English (not sure about the quality of the translation and if it contains the latest amendments to the law): http://www.gesetze-im-internet.de/englisch_urhg/englisch_urhg.html#p0246 http://www.gesetze-im-internet.de/englisch_urhg/englisch_urh...