SOAS University of London

School of Law

International and Comparative Copyright Law: Copyright in The Global Village

Module Code:
Taught in:
Full Year

This module aims to provide a comprehensive outline of copyright law in today’s world. It is of a comparative nature: the UK has been chosen as the jurisdiction where copyright law originated; the USA as the world’s biggest exporter and importer of copyright works; and France as the most influential droit d’auteur system of copyright.

In respect of international legislation, since the Berne Convention and the WIPO Copyright Treaty represent the international standard par excellence for the protection of authorship, reference will be made frequently to the relevant provisions of these two international instruments. Similarly, essential references to other international instruments such as the TRIPS Agreement, the Rome Convention for the Protection of Performers, Producers of Phonograms and Broadcasting Organisation will be made.

No prior knowledge of copyright/droit d’auteur is required.

Objectives and learning outcomes of the module

The aims of the module are:

  • to introduce the students to the differences that exist between the copyright system and that of the droit d’auteur, especially in respect of subject matter, originality, authorship, and ownership;
  • to consider the scope of protection offered to copyright works in the UK, USA and France;
  • to consider the historical origin and evolution of the international standards of protection, as reflected in the Berne Convention, the Universal Copyright Convention, TRIPS and the WIPO Copyright Treaties; and
  • to reflect upon the EU harmonisation process and to assess whether it adequately accommodates different legal traditions.

At the end of the module a student should have a good knowledge and understanding of:

  • the different types of subject matter protected by copyright/droit d’auteur, including cinematographic works and software;
  • the availability and scope of protection and how different doctrines, such as the fair use in the USA and the fair dealing in the UK, exempt certain types of use from copyright liability; and
  • the problems and opportunities raised by digital technology/internet, and the legal responses adopted at the European and international levels.

Method of assessment

  • Unseen written exam: 100%

Suggested reading

Ricketson and Ginsburg, International Copyright and Neighbouring Rights: The Berne Convention and Beyond, 2nd ed. (OUP, 2005).


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