Copyright reform part II: Harmonizing copyright law.

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When I last wrote about copyright reform it was about making copyright manageable such that the owner can be identified and rightly compensated. However, one significant problem remains:

Copyright law varies from country to country, even within the EU. Efforts have been made to harmonize the copyright laws, but leaves room for national variations. This is a problem when content is published on-line: Which copyright law applies?

  1. The copyright in the country where the work was created?
  2. The copyright in the country where the work is hosted?
  3. The copyright in the country where a person access the work?

We can't assume people will understand these subtleties of copyright law, and we can't expect people to seek legal advice before publishing their home made videos from their summer vacation online.

To avoid such complexities, copyright must be harmonized further than is currently the case, and where this is not possible, the above question must no answered.