A Comparative Study of the 'Reproduction by Natural Persons for Private Use' Exception to Copyright in the UK and France

摘要

The "reproduction by natural persons for private use" exception to copyright was intended to be harmonised in the EU in 2001, but since then many differences have arisen among the Member States in its regulation. In this article the main elements of this exception as introduced in the UK and France will be studied, following the communitarian framework and developments in recent case law. This comparative investigation will serve to point out the differences, strengths and weakness of the singular systems in place in these two countries, and to identify the areas of future development that this exception could potentially experience, as upcoming legislative adjustments are expected in both countries in this matter.