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By Anonymous writer - Glossary

Copyright is the general term used in common law jurisdictions to describe the French (and other civil law systems) equivalent of authors’ rights (‘droit d’auteur’ in French). While there are differences between these two legal regimes, both in terms of their historical legal development and current application, it is important not to exaggerate their distinctions. Indeed, both systems are similar in that they provide protection to the author or creator of a work and accords them certain rights, like the ability to transfer or license the work. Similarly, both systems have been influenced by one another. For instance, while historically moral rights did not come under copyright law, they are now included in copyright jurisdictions such as the UK.

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