Moral Rights 2.0

Moral Rights 2.0
Peter K. Yu

ISBN 978-90-411-3343-4
Kluwer Law International BV, The Netherlands

In his Chapter, Andre´ Bertrand provides an excellent discussion of Soc. Le Chant de Monde v. Soc. Fox Europe1 (Shostakovitch) and Turner Entertainment Co. v. Huston2 (Huston) – two cases that US courses on international and comparative intellectual property law have frequently covered. These two cases provide excellent illustrations of the differences between continental Europe and the United States concerning the protection of moral rights.3 While the Anglo-American copyright regime and the French author’s right (droit d’auteur) regime were quite similar in the eighteenth century, the protection of moral rights did not attain formal international recognition until 1928.5 The gap between the US and French systems has also grown considerably since the enactment of the 1909 US Copyright Act.