[47282847]

In that line of reasoning, does it really matter how “close“ jurisdictions are to each other — also considering how what courts rule doesn’t matter as much in countries governed by civil law - but merely the enforcement of the Berne convention? As in, if something is considered to be under copyright in any one of all the signatory countries of it, the others have to respect that?

[skissane]

No, the Berne convention doesn’t work that way. It requires you to extend copyright protection to the works of the nationals of the other parties on the same terms as you offer it to the works of your own nationals; but if a certain category of works are excluded from copyright for your own nationals, it doesn’t require you to recognise copyright in those works when authored by foreign nationals, even if their own country’s laws do

Real example: UK law says telephone directories are eligible for copyright, US law says they aren’t. The US is not violating the Berne convention by refusing to recognise copyright in UK phone directories, because the US doesn’t recognise copyright in US phone directories either. A violation would be if the US refused to recognise copyright in UK phone directories but was willing to recognise it in US ones

[47282847]

Makes sense. Thanks!