Christina Angelopoulos has self-archived "The Myth of European Term Harmonisation: 27 Public Domains for the 27 Member States" in SSRN.
Here's an excerpt:
The term of protection of copyright and related rights is generally considered to be one of the best harmonised areas of European copyright law. However, close examination of the EU Term Directive's intricate provisions reveals a piecemeal and permissive approach to harmonisation which preserves many differences between the national rules. In this report, four main sources of legislative variability are identified and analysed: a) contagion from unharmonised areas of substantive copyright law; b) explicit exceptions to the harmonisation of the term of protection; c) national related rights of unharmonised term; and d) incorrect implementation of the provisions of the Term Directive into national law.
| Digital Scholarship's Digital/Print Books | Digital Scholarship |
