Comparative analysis of the copyright law relating to films between the United Kingdom and the Federal Republic of Germany

The thesis decscribes the philosophical foundations and the historical developments which led to the current state of law in both countries. It evaluates the substantive provisions of the two laws, its distinct aspects as well as its divergences which are a result of different philosophies underlying each national copyright system. The thesis concentrates on the following areas: definition of film, persons qualifying for authorship, duration of copyright, economic and moral rights, defences and remedies for infringement of film copyright. The impact of digitisation on copyright law and its positive and negative effects are explained. Besides, the thesis devotes itself to digital management systems. The thesis also focuses on film distribution and community policies. It describes the European provisions on free movement of goods and services and on competition law as well as the opposing influence of national copyright law. Relevant case law of the European Court of Justice is evaluated and European programmes for the audiovisual sector are described. Furthermore, international and European law, such as the Berne Convention, the Rental and Lending Right Directive, the Satellite Broadcasting and Cable Retransmission Directive, the Directive Harmonising the Term of Protection, the Information Society Directive and the Enforcement Directive are critically examined. Their influence on and the consequential changes to United Kingdom and German copyright law are analysed while special regard is taken to whether national legal understandings are appropriately appreciated.EThOS - Electronic Theses Online ServiceGBUnited Kingdo