On 05/06/07, MJ Ray <mjr@phonecoop.coop> wrote:> Small excerpts (e.g. an Emacs reference card from the Emacs info docs) > are probably covered under Fair Use. [...] This is England calling.Would the FSF have to sue under US law or UK law an offender in the UK? I'm genuinely ignorant about this issue.
English law.The UK is not England. The UK does *not* *have* a legal system, as legally it is two kingdoms, each with their constitutionally guaranteed separate legal systems (think of it as if the US congress could pass state laws that applied in one or other state, but could not pass laws which applied to the entire US as a whole. Weird, I know, but it's the system we have).
The UK (yes I know I said we don't have a legal system) is a signatory to Berne, which merely guarantees that a foreigner has the same rights as the locals. So, as a USian, you can sue in the UK with exactly the same rights as a UK subject would have. Which is why, if as a UKian I want to sue in the US, I have to register my copyright with the Library of Congress just like you have to do.
Cheers, Wol -- Anthony W. Youngman - anthony@thewolery.demon.co.uk