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Re: [tlug] Novel embraces Microsoft



Keith Bawden writes:

 > As far as I know copyright law is now set up in such a way that the
 > explicit "rights" established by a copyright granted in one jurisdiction
 > are automatically "reserved" in all International jurisdictions[1].

Not quite.  WIPO among others requires certain minimum grants to
participate, but in general the rights that you get in one
jurisdiction are defined by that jurisdiction.  That's why the U.S. is
being so pushy about everybody signing up on software patents; if a
country doesn't grant software patents, an American patentee gets no
protection in that country.  Copyright is different because the
various treaties all require that copyright be automatic, but the
difference in local law still means that a German can sell his whole
copyright in the U.S., even though he cannot sell his author's moral
rights in Germany.


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