While Theo is very intelligent and opinionated it is important to mote he is not a lawyer. His understanding of law should be taken with a grain of salt.
True. Most of the world use Civil Law, while US, UK and a few former colonies use Common Law. And Civil Law is quite different in different parts of the world. In other words: GP:s statement IS true.
For instance, according to the french and the scandinavian copyright traditions (which is a slightly more complicated topic, since it is not divided only into common and civil law, but instead into english, american, french and scandinavian law - however, the two common law countries have similar ideas to each other, and so does the two civil law countries), it is not possible to sign away your copyright at all, since it's not considered to be an economical thing (Victor Hugo created the french version, primary about the moral right to be honored and paid for your work, and the scandinavian version is based of old Westrogothic law, that said something to the effect of "honor he who should be honored", which doesn't even mention money, but only honor), unlike the tradition in US and UK. It is possible to sign away economical rights, but not the whole thing. This has some important effects: one thing is that it makes it impossible for RIAA/MPAA to go after people in this part of the world - they only represent the companies, whose contracts with the employees are illegal over here, and they therefore have no copyright to enforce.
Theo is not a lawyer (Score:1, Insightful)
Re: (Score:0, Troll)
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Re:Theo is not a lawyer (Score:2)
For instance, according to the french and the scandinavian copyright traditions (which is a slightly more complicated topic, since it is not divided only into common and civil law, but instead into english, american, french and scandinavian law - however, the two common law countries have similar ideas to each other, and so does the two civil law countries), it is not possible to sign away your copyright at all, since it's not considered to be an economical thing (Victor Hugo created the french version, primary about the moral right to be honored and paid for your work, and the scandinavian version is based of old Westrogothic law, that said something to the effect of "honor he who should be honored", which doesn't even mention money, but only honor), unlike the tradition in US and UK. It is possible to sign away economical rights, but not the whole thing. This has some important effects: one thing is that it makes it impossible for RIAA/MPAA to go after people in this part of the world - they only represent the companies, whose contracts with the employees are illegal over here, and they therefore have no copyright to enforce.
Finally, a pretty map to show what legal systems exists where: http://upload.wikimedia.org/wikipedia/commons/2/21/LegalSystemsOfTheWorldMap.png [wikimedia.org]