Copyright assignment

Claus Färber list-fsf-eu-discussion at
Sat Jun 15 13:25:00 UTC 2002

Joerg Schilling <schilling at> schrieb/wrote:
> From my understanding, all progressive (so probably all continental european)
> countries use a law definition derived from ideas of the french revolution
> while the UK is still using laws derived from the roman law.

While it is true that Continental authors' rights ared based on ideas
from the French Revolution, UK laws have never been influenced much by
Roman Law. On the contrary, the UK legal system is based on the Common
Law, which is completly different from the Continental-European Civil
Law systems (or ius civile), which were derieved from the Roman Law.

The Anglo-American copyright system stems from censorship laws; you had
to get a licence from the monarch to publish books. This license often
granted exclusive rights to copy that particular book.

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