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by graemep 834 days ago
Maybe some European countries, but copyright law varies across Europe.

You can definitely transfer copyright in the UK, rather than an exclusive license.

You might be confusing copyright with moral rights which are not transferable but I believe that is the same in the US.

1 comments

I was simplyfying. What I described is unified in the European Union; however, the outlined distinction is common across the roman-germanic law system whereas the US copyright interpretation is rooted in common law. In Europe, the only countries using common law are UK and Ireland. And while Ireland has mostly unified their copyright law with the rest of the european union, you still see some roots in common law. For example, it is possible that an irish company (a legal person) can become an author of a work, which is impossible under e.g. german law.

And yes: in a common law system, copyright governs literally "the right to copy", which is transferable. In other law systems (which is the distinction I made) the law governs the property rights of the author's expression, which is non-transferrable, you can only license the rights you have.