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by aleph_minus_one 325 days ago
#include <Usual IANAL comment>

> In the US usage like this may be considered "Fair Use", however UK copyright law is less generous in its "Fair Dealing" and associated exceptions to copyright[1].

> This is a problem when standards are pushed by US tech companies but don't consider the rest of the world.

Similarly, the German analogue to the US-American copyright laws (Urheberrecht) has no concept of fair use (meaning that a lot of memes that are based copyrighted material are actually illegal under German law), but on the other hand, as far as I am aware (IANAL), there is more explicit permissions for citations (Zitierrecht) in Germany (instead of relying on "vague" concepts such as fair use), meaning that I conceive at least fictional situations (but IANAL) where it might happen that quotations of copyrighted material are legal under German law, but not considered to be "fair use" under US copyright.