Re: [Fsfe-uk] Re: [Debian-uk] Free software and UK law

[Ralph Janke]

Space Bunny wrote:

> I asked a lawyer friend and this is what he said, but I  guess from 
> replys since you have access to more informed people.
> But here was his reply for your info.
>
> cheers,
>
> Micah
> http://j12.org/sb/
>
> http://www.machinista.org
>
>
>
> -------- Original Message --------
> Subject:     Re: [Fwd: [Fsfe-uk] Re: [Debian-uk] Free software and UK 
> law]
> Date:     Thu, 29 Apr 2004 16:39:36 +0100 (BST)
> From:     Julius Komorowski <address@hidden>
> To:     Space Bunny <address@hidden>
>
>
>
> Dear Micah,
>
> License law really isn't my thing but as copyright is
> determined by the Berne Convention anything effective
> in one country is likely to be so in another.  There
> are no material differences with Scottish and English
> law on this point.
>
> [...]
>
> Take care-
> Julius.

It is not only defined as described here by the Berner convention and 
therefore through the international law in form
of the treaty of the Berner converntion valid in all participating 
countries, but also written in a directive (if I remember correctly)
in EU law. Since EU law is according to the European Court of Justice 
always prevailing over national law, it would certainly
be equal in England and Scotland despite the different law systems of 
England and Scottland.