[djoldman]

That's an interesting perspective, and yes wholly foreign to my very American economics influenced background.

Are the origins the same when looking at other intellectual property like patents?

How did they deal with quoting and/or critiquing other's ideas? Did they allow limited quotation? What about parody and satire?

[capnrefsmmat]

I'm not sure about other intellectual property rights. I do know there's a similar dichotomy for privacy: Americans tend to view it in terms of property rights (ownership of your image, data, etc.) while Europeans view it as a matter of protecting personal dignity. That leads to different decisions: for instance, there's a famous French case of an artist making a nude sketch of a portrait subject, and being unable to sell the sketch because it violated the subject's privacy rights, despite being the owner of the intellectual property.

Peter Baldwin's Copyright Wars is a good overview of the European vs American attitudes to copyright in general.

[djoldman]

Thanks. I put it on hold at the library.