Jan Schaumann a écrit :
Just the other day I found out that in Germany, there is no such thing as a "Copyright" - the "Copyright" is an american thing. The closest thing in Germany would be the "Urheberrecht", IIRC.
Neither in in France ;)
Now my question is, if there is no equivalent to the US-Copyright, does the GNU GPL hold in Europe?
I think that nothing refers in the GPL directly to any precise american copyright law. Instead, the GPL grants the user some right, and prevents others to prevent this (in french, in '68 they had a moto : "Il est interdit d'interdire" ;)... and this has not really anything to do with copyright, as it is a licence contract that both parts (or I should say many parts) agree on in using and distributing the software.
So, the absence of copyright notion in the European law systems is not a restriction preventing us to use the GPL. Many other issues though could diminish the GPL's efficience here, but it's another question ;)
Of course, IANAL, so I'd be interested in some responses from people with a clue, who are able to explain things in laymens terms.
Hmm... these are only my understandings and I'm no law professionnal, just a free software user and programmer... so correct me if I'm wrong.