The majority of copyright-protected works are created on a contractor or employment basis. In addition, the cross-border use of works has increased. In this book, Maria Ottermann examines how the Urheberrecht in Germany, the copyright law in England and the auteursrecht in the Netherlands resolve conflicts in the distribution of copyright in employer or contractor relationships. She clarifies to what extent the statutory differences in the allocation of original ownership and the scope of moral and exploitation rights can be aligned on a contractual basis. A further focus of this book lies in an examination of the national conflict of laws applicable in Germany, England and the Netherlands and the approaches of the principles of country of protection and country of origin which they represent. The author points out the areas in which European-wide harmonisation would be desirable in this respect.
The Significance of the Country of Origin Principle for the Conflict of Laws Issue of Unfair Commercial Practices
