From: John Cox <[log in to unmask]>
Date: Tue, 6 Dec 2016 10:36:21 +0000

UK copyright law follows the same logic and contains similar
provisions to US copyright law, as both the UK and the USA (as well as
most other countries) are signatories to the Bern Convention and are
members of the World Intellectual Property Organisation (WIPO).  UK
copyright law is broadly the same as copyright laws in other member
states of the European Union under the European Copyright Directive.

UK and US copyright law differ in two respects:

a.  US 'fair use' is generally seen as broader than UK 'fair dealing'
and 'library privilege'.  In practice, there is probably not much to
worry an academic library.

b.  UK, like European, copyright law recognises 'moral rights', which
US law does not.  Moral rights belong to the author, and protect the
author's right to be identified with the work and ensure that the work
is not distorted. It demands no more of the publisher or user than
honesty and decency require.

I have worked with US libraries and library organisations such a CARL
for the past 25 Years, and have never encountered a copyright problem
with a UK work that would not have arisen had it been published in the
USA. So there should be absolutely no problem.

John Cox
Rookwood, Bradden
Towcester, Northants
NN12 8ED
United Kingdom

Tel: +44 (0) 1327 861184
Email: [log in to unmask]


-----Original Message-----
From: Terry Leopold <[log in to unmask]>
Date: Thu, 1 Dec 2016 22:37:31 +0000

[MOD NOTE:  A good question, but it received no liblicense-l
responses.  Anyone out there have any words of wisdom?]

We've been asked to sign a license from a company in the U.K. which
binds us to U.K. copyright law.  Here's the passage:

"This Agreement shall be deemed to complement and extend the rights of
the Institution and Authorised Users under the United Kingdom’s
Copyright, Designs and Patents Act 1988 and Copyright (Visually
Impaired Persons) Act 2002 and nothing in this Agreement shall
constitute a waiver of any statutory rights held by the Institution
and Authorised Users from time to time under these Acts or any
amending legislation."

Does anyone have any insight as to whether we should accept this?  I
don't know if U.K. and U.S. copyright law are similar enough for us to
agree with this, or whether we should ask that it be struck and
replaced with a referenced to U.S. law.

Thanks for any help you can offer.

Terry Ann Leopold
E-Resource Manager
Colorado Alliance of Research Libraries
3801 E. Florida Ave., Suite 515
Denver, CO  80210
[log in to unmask]
Phone - 303.759.3399, ext 111. Fax – 303.759.3363