[zimpenfish]

> How does the copyright system in Luxembourg work?

They're signatories to the Berne Convention[1] which gives you automatic copyright on "every production in the literary, scientific and artistic domain, whatever the mode or form of its expression" and also gives you control over rights for "the right to make adaptations and arrangements". Which I would understand to mean they can't say "copyright is void because of XYZ" - it was created, it is copyrighted. I'd imagine WIPO would slap this down.

> As far as I know the US copyright system is very different from that, where you have to register or apply

Since they're signed up to the Berne Convention, copyright is automatic but apparently there is an allowed "requirement that the right holder of a “United States work” have registered the work before initiating a lawsuit" (from [2])

[1] https://www.wipo.int/treaties/en/ip/berne/summary_berne.html

[2] https://www.mediainstitute.org/2009/10/20/borderless-publica...

[Sujan]

Thank you so much for doing the research and explaining this.

Then the "German" way of doing things is actually _the_ way of doing things, and the US just hase some additional stuff on top.

That also clarifies the twitter thread to me: This was about a _court_ ruling, not some copyright office deciding if something is copyrighted or not (which I assumed because I thought about the German way being special, and my misguided understanding of the US system being the international standard).

I also realize now that further down the twitter thread this is made more explicit. I should really have read more then the first 5 tweets. Sorry.