logoalt Hacker News

GuB-42last Saturday at 1:37 AM1 replyview on HN

If France, fair use doesn't even exist!

We have exceptions, which are similar, but the important difference is that courts decide what is fair and what is not, whereas exceptions are written in law. It is a more rigid system that tend to favor copyright owners because if what is seen as "fair" doesn't fit one of the listed exceptions, copyright still applies. Note that AI training probably fits one of the exceptions in French law (but again, it is complicated).

I don't know the law in other European countries, but AFAIK, EU and international directives don't do much to address the exceptions to copyright, so it is up to each individual country.


Replies

mikae1last Saturday at 8:03 AM

> If France, fair use doesn't even exist!

Same in Sweden. The U.S. has one of the broadest and most flexible fair use laws.

In Sweden we have "citaträtten" (the right to quote). It only applies to text and it is usually said that you can't quote more than 20% of the original text.