ABSTRACT
Although the international conventions require certain minimum standards of protection to be provided by all their signatories, the approach to protection of literary, artistic and musical works can vary quite considerably from one country to another. In the UK copyright has long been treated almost as a commodity: the law is concerned above all with the economic exploitation of a piece of property, and copyright extends beyond works of authorship to what in some countries are not regarded as subjects for copyright but are described as 'related rights' or 'neighbouring rights', such as sound recordings, films or broadcasts. True, the particular qualities of intellectual property require that it cannot be treated in exactly the same way as a pound of sugar or a piece of furniture, but it is only grudgingly and recently, in the Copyright, Designs and Patents Act 1988, that the law has admitted moral rights for the writer, artist or composer, over and above the purely economic rights. By and large, the other Common Law countries, those countries which derive their legal systems from the English Common Law, most of the Commonwealth, as well as the USA, have tended to take the same approach. This chapter will illustrate the different ways in which the copyright laws operate in a few selected countries.
