TY - GEN N2 - This unique new information source compares moral rights in more established civil law jurisdictions with those in less developed common law countries. The situation in the UK is contrasted with that in the major jurisdictions of France, Germany, Canada, Australia and the USA, along with several secondary jurisdictions.Including areas such as copyright, the paternity right, the right to privacy and transmission of moral rights, this book provides a practical and comparative approach to a topic about which little has been written. A unique work explaining the full implications of moral rights Deals with the gap in knowledge in the UK of moral rights elsewhere Includes some of the significant amount of case law in civil law jurisdictions. AB - This unique new information source compares moral rights in more established civil law jurisdictions with those in less developed common law countries. The situation in the UK is contrasted with that in the major jurisdictions of France, Germany, Canada, Australia and the USA, along with several secondary jurisdictions.Including areas such as copyright, the paternity right, the right to privacy and transmission of moral rights, this book provides a practical and comparative approach to a topic about which little has been written. A unique work explaining the full implications of moral rights Deals with the gap in knowledge in the UK of moral rights elsewhere Includes some of the significant amount of case law in civil law jurisdictions. T1 - Moral rights. AU - Gillian, Davies., AU - Garnett, K. M. AU - Davies, Gillian. CN - K1430 N1 - Part I: The nature and origins of moral rights Origins of the theory of moral rights The International development of moral rightsIn civil law countriesThe monistic theory of copyrightThe dualist theory of copyrightIn common law countriesMoral rights in international instrumentsThe Berne ConventionThe WIPO Copyright Treaty 1996The WIPO Performances and Phonograms Treaty 1996The TRIPS Agreement 1994Moral rights in regional conventionsCouncil of Europe treatiesEC policy on moral rightsPart II: Moral rights in the United Kingdom Historical treatment of UK protection down to CDPA 1988, plus outline of subsequent amendments IntroductionThe four rights protected as moral rights by statuteThe requirement of a copyright workThe requirement of a qualifying performanceProtection by other causes of actionThe concept of a copyright workClassification of protected worksThe requirement of fixationThe requirement of originalityQualifying conditionsForeign worksWorks denied protectionThe concept of authorship in relation to a copyright work. N1 - The concept of a performerWhat is a performance?Who is the performer?Qualifying performancesPart III Treatment of moral rights in other jurisdictions EUROPEBelgium France Germany Greece Italy The Netherlands The Nordic Countries (Denmark, Finland, Norway and Sweden) PortugalSpain Switzerland RussiaOTHER COUNTRIES/REGIONSAustralia Canada China and Hong KongIndia IsraelJapan Latin America United States of AmericaRest of World. ID - 26181 KW - Copyright KW - Copyright KW - Moral rights KW - European Union KW - Droit d'auteur SN - 9780421729407 TI - Moral rights. ER -