From: Georg Jakob jack@unix.sbg.ac.at
There is *no* Copyright in Europe. In most european countries we have the concept of Authors Rights. Difference in a Nutshell: Copyright is protecting the editor or publisher of a work, ie his (monetary) investment in producing copys. That's why it's called "Copyright".
The official translation for "Urheberecht" unfortunately _is_ "Copyright". However this is bad as Copyright is only a part of what I call "Authorship Right". "Authorship Right" cannot be transferreed.
And this is one of the big problems when taling to FSF in USA. They generally like you to transfer the Copyright to FSF wich cannot be done as long as you write the contract on English because this language does not have the right words to express the real factual situation.
Jörg
EMail:joerg@schily.isdn.cs.tu-berlin.de (home) Jörg Schilling D-13353 Berlin js@cs.tu-berlin.de (uni) If you don't have iso-8859-1 schilling@fokus.gmd.de (work) chars I am J"org Schilling URL: http://www.fokus.gmd.de/usr/schilling ftp://ftp.fokus.gmd.de/pub/unix
Joerg Schilling schilling@fokus.gmd.de writes:
The official translation for "Urheberecht" unfortunately _is_ "Copyright". However this is bad as Copyright is only a part of what I call "Authorship Right". "Authorship Right" cannot be transferreed.
I think the proper term for these rights is "moral rights".
And this is one of the big problems when taling to FSF in USA. They generally like you to transfer the Copyright to FSF wich cannot be done as long as you write the contract on English because this language does not have the right words to express the real factual situation.
A solution for German citizens is under way.