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The article titled "Law Libraries, Copyright and Digital Lending" aims to bring to the fore copyright issues related with digital lending by law libraries and is a comparative study of the copyright law of India and the United States. Accordingly, this piece will analyze the situation in two jurisdictions—India and the United States to understand the facilitation of digital lending by law libraries, particularly during the COVID‐19 pandemic. It will look at some key concepts such as publication, distribution, reproduction, controlled digital lending, fair use, fair dealing, public interest, exhaustion, and copyright infringement. To understand the practice of digital lending by law libraries in India and controlled digital lending in the United States the author interviewed a few librarians from both countries and learnt about the challenges faced by librarians to facilitate digital lending. The author also learnt that while librarians in the United States practice controlled digital lending, librarians in India do not; they practice only digital lending. Testimonies of librarians and analysis of the present law and precedents in India and the United States led the author to understand that there is no concrete law on digital lending by law libraries at present in the two jurisdictions. Accordingly, this article discusses the utility and necessity of digital lending by law libraries in the present times, as also that of controlled digital lending. [ABSTRACT FROM AUTHOR]

In 2018, the University of Winnipeg Library introduced the Syllabus Service to improve the course reserves submission process. This initiative has allowed library staff to proactively support copyright in e-reserves and provided opportunities to improve accessibility for students. The service has also encouraged faculty and instructor use of course reserves by reducing the time and effort required to submit requests, and has eased the workload of reserves staff by leveraging the expertise of the Copyright Office. [ABSTRACT FROM AUTHOR]

Copyright protection is a legal force which has the power to encourage creators/authors by creating propriety rights in intangible assets. However, its purpose is not limited to serving creators. It also has the onus to balance out the interests of the society by ensuring reasonable access of ideas to the public at large. Moral rights and fair dealing exist at the two extremes of this incentive-access balance, necessitating friction in certain cases. This paper is aimed at highlighting a gap in the Indian legal context, where moral rights have become broad enough to pose a threat to fair dealing, particularly criticism, which is one of the most important aspects of development in any field. Pursuant to this aim, the paper puts forward an argument to subjugate moral rights to fair dealing through legislative amendments. Further, it suggests two judicial standards to navigate through the grey waters of the aforementioned friction. [ABSTRACT FROM AUTHOR]

As technological developments continue to disrupt creative industries, they put to test our copyright doctrine. The recent litigation initiated against Sci-Hub and LibGen by three publishers raises complex questions permeating the Indian copyright regime. In this context, it is important to determine the values our copyright system serves and the standards of 'fairness' it demands to exempt certain infringements. This paper studies the Indian fair dealing jurisprudence from a theoretical standpoint to argue that it lacks a robust normative foundation. It first maps the prevalent theories of copyright and suggests that the cultural theory not only exposes gaps in the dominant incentive theory but also offers a more comprehensive understanding of copyright. It then analyses Indian fair dealing cases from this viewpoint. While the jurisprudence is largely inconsistent, analysis of two important cases reveals that while their outcome was desirable from a cultural theory perspective, their doctrine is insufficient to excuse certain socially-valuable infringements. Their emphasis on transformativeness coupled with an implicit bar on verbatim reproductions is critical. It is suggested that the Indian fair dealing jurisprudence is unfit to foster a just and attractive culture; one that strives to attain pluralistic values essential for the 'good life'. [ABSTRACT FROM AUTHOR]

Copyright exceptions for teaching and research purposes have turned into a significant issue for achieving a balance between the copyright owner and copyright users. The regulation of this issue is reflected in the Copyright Acts 1911 and 1987 for Palestine and Malaysia, respectively. The Palestine Copyright Act 1911 dismisses teaching and research copyright exceptions in detail and has not been amended since 1911; signifying a huge setback in regulating this issue and the pressing need to improvise the Act in order to achieve a balance between the copyright owner and copyright users. The present study has looked into the teaching and research exceptions detailed in the Palestine Copyright Act 1911 with the aim of suggesting improvements in the Act. The comparative research approach was used, along with a functional method. The findings revealed that the Malaysia Copyright Act 1987 offers several provisions in regulating the teaching and research exceptions based on a fair dealing rule, while the Palestine Copyright Act 1911 lacked provisions in regulating these exceptions despite its fair dealing principle. This points to the need for improvements in the Palestine Copyright Act 1911.

This article maps the latest developments in South Africa’s complex battle to update its Copyright Amendment Bill across a path strewn with legal pitfalls. Driving the agenda of the American-derived “fair use” and other copyright exceptions at the expense of content creators are the state, under the guise of “access” to education, and Big Tech companies focused on data mining, paraded as users’ rights to content. The emerging Bill has given rise to a set of major contradictions that will directly and negatively impact especially educational book publishing, from primary to tertiary sectors. The updated Bill risks violating authors’ rights and international treaties. The authors identify contradictions in public policy and sketch the most contentious aspects within debates around the Bill. The implications for the national research economy are considered, while the need to adequately protect the copyright of open access content is raised. The article closes with a summary of the issues of “fair use” and fair dealing, the predatory implications, and the outcome of the contradictions for the industry. The relevance of writing about a moving target is because a) the Bill has been in contestation for eight years now; b) universities and the whole educational sector have failed to respond coherently to the threats portended in the Bill; c) the nature of the claims and counter-arguments raised by the Bill will continue well after it has been promulgated; and d) the analysis is alert to open access imperatives and to the threat of South Africa becoming a haven for servers hosting pirated content should the Bill become law. [ABSTRACT FROM AUTHOR]

The South African Copyright Amendment Bill of 2017 was passed in 2022. In justifying the weakening of copyright protections with regard to the educational arena, the Bill's proponents have largely applied rhetorical discourses published in the popular media, also aggressively propagated at their public meetings. In contrast, the publishing industry has generated many hundreds of pages of economic impact studies supported by detailed legal arguments with reference to global treaties. My analysis assesses the different positions taken by the pro-Bill lobby, ReCreate, in comparison to the Copyright Coalition that questions the importation of an American fair use doctrine. The potential implications of the Bill for South African authors and artists operating in the educational environment are described. Since the object of study has been a moving target, and still was at the time of submission of this article, the conclusions that arise out of the ongoing debates are tentative - but prescient for the current conjuncture. The analysis relies on cross-referencing stakeholder submissions, newspaper articles and statements made by all parties to the discussion. In addition, a number of rejoinders were invited, which are published below. The study reveals the stark contradictions within emerging state policy relating to the creative industries in an era when information has economic value. My conclusions are that: a) a significant portion of the state publishing incentive that currently finances research activities would be in the parallel context of open access rerouted to meet publication charges, were the Bill to be enacted in its current form; and b) the effects might witness: i) a swing away from the publication of homegrown textbooks in favour of copyright-protected expensive imports; with clear implications for the ii) de-colonisation of content; iii) a reluctance of international firms to collaborate with South African publishers; and iv) a significant contraction of the South African publishing industry. And c) while the Creative Industries Masterplan piloted by the Department of Small Business Development (DSBD) aims to protect intellectual property rights, the Bill will undermine such rights. [ABSTRACT FROM AUTHOR]

This paper explores legal considerations for how libraries in Canada can lend digital copies of books. It is an adaptation of A Whitepaper on Controlled Digital Lending of Library Books by David R. Hansen and Kyle K. Courtney, and draws heavily on this source in its content, with the permission of the authors. Our paper considers the legal and policy rationales for the process—“controlled digital lending”—in Canada, as well as a variety of risk factors and practical considerations that can guide libraries seeking to implement such lending, with the intention of helping Canadian libraries to explore controlled digital lending in our own Canadian legal and policy context. Our goal is to help libraries and their lawyers become better informed about controlled digital lending as an approach, offer the basis of the legal rationale for its use in Canada, and suggest situations in which this rationale might be strongest.

The paper examines the open access movement and its principles concerning creative outputs and related access opportunities, considering copyright protection. The international and ongoing integration of open access practise has brought about a reconsideration of foundational principles of copyright law. The paper's discussion considers the three-step test legal edifice, which is deeply rooted in international copyright law, and argues that its importance and application is of paramount importance regarding potential revisions of copyright law that would need to introduce open access provisions. [ABSTRACT FROM AUTHOR]

The prevailing dynamics of today’s global scholarly publishing ecosystem were largely established by UK and US publishing interests in the years immediately after the Second World War. With a central role played by publisher Robert Maxwell, the two nations that emerged victorious from the war were able to dilute the power of German-language academic publishing—dominant before the war—and bring English-language scholarship, and in particular English-language journals, to the fore. Driven by intertwined nationalist, commercial, and technological ambitions, English-language academic journals and impact metrics gained preeminence through narratives grounded in ideas of “global” reach and values of “excellence”—while “local” scholarly publishing in sub-Saharan Africa, as in much of the developing world, was marginalised. These dynamics established in the post-war era still largely hold true today, and need to be dismantled in the interests of more equitable global scholarship and socio-economic development.

Fair dealing is one of the important elements in the Industrial Design Legislation. Because of that, it is significant to analyze the concept of fair dealing which can be understood by the society to achieve fairness in the protection of industrial design works. Under industrial design, the concept of fair dealing means that industrial design can be used by other parties for education and research purposes as long as it does not prejudice the interests of industrial design right holders. The purpose of this study is to analyze the value of fairness in the concept of fair dealing in industrial design law, so that it can be used as guidelines for the right holders and the public so they not violate the Industrial Design Law and this Law can also be used to advance the welfare of society. This study is normative legal research by using statute and conceptual approaches. While material used for this study are primary and secondary legal materials. This study found that fairness in the fair dealing in the protection of industrial design can be achieved in the form of fulfilment of balance rights between the designer’s right and society. Fairness for both is if between the right holder and society have the opportunities to use and enjoy available industrial design. Industrial design rights holders have limited monopoly rights and the public has the opportunity to use the results of industrial design in a limited manner for their welfare. This is in line with what Aristotle said that justice is given in accordance with values or propriety that is not the same.

This paper explores legal considerations for how libraries in Canada can lend digital copies of books. It is an adaptation of A Whitepaper on Controlled Digital Lending of Library Books by David R. Hansen and Kyle K. Courtney, and draws heavily on this source in its content, with the permission of the authors. Our paper considers the legal and policy rationales for the process--"controlled digital lending"--in Canada, as well as a variety of risk factors and practical considerations that can guide libraries seeking to implement such lending, with the intention of helping Canadian libraries to explore controlled digital lending in our own Canadian legal and policy context. Our goal is to help libraries and their lawyers become better informed about controlled digital lending as an approach, offer the basis of the legal rationale for its use in Canada, and suggest situations in which this rationale might be strongest. [ABSTRACT FROM AUTHOR]

Indian Copyright Act, 1957 provides a private right in copyright which extensively deals with provisions that guarantee access to knowledge as well. Copyright is an exclusive and assignable legal right given to the author for a particular period for original literary, dramatic, artistic works, and musical work whether published or unpublished. These rights are not absolute but subject to restrictions and limitations imposed by law. Section 52 of the Copyright Act, 1957 is one such provision that restraints the exclusive enjoyment of rights given to the copyright holder. As per Section 52 (1)(o) of the Copyright Act, 1957 a non-commercial library is permitted/allowed to make three copies of a book for library use, provided such books are not available for sale in India. The present article is about the concept of fair dealing which is originated from the Common of laws of England. Although, the concept of fair use and fair dealing are used synonymously, the Indian Copyright Act, 1957 deals with fair dealing under Section 52 of the Copyright Act, 1957. The reproductions of works for research or private study, taking photocopy for research and educational purpose, etc., are covered under the doctrine of fair use. This paper will explain the conceptual framework of the Indian Copyright Act and the empirical reality in libraries of Maharashtra. It attempts to empirically test the usage of fair use provisions under the Indian Copyright Act and the awareness among librarians of Colleges and Universities in Maharashtra. The research methodology used for the present study is both doctrinal and non-doctrinal. It was observed that most of the librarians are aware of Copyright Law and copyright exceptions but when it comes to the implementation librarians also face difficulty and it leads to the infringement of copyright. [ABSTRACT FROM AUTHOR]

During the recent COVID-19 pandemic, amateur writers have increasingly been reusing characters, locations, and plotlines from commercially successful works to bring alternative viewpoints and storylines to life. This type of user-generated content is called fanfiction, produced mostly for free online on websites such as Fanfiction. Net as a method of escapism and communication. This is one of many uses of the Internet which raises issues in relation to copyright in a digital market, and how it interacts with freedom of expression. Copyright theory tells us that by protecting the author's natural rights to control their works, we also protect that author's ability to express themselves. Yet, by limiting what can be done with their work, we are limiting the freedom of expression of later authors. This article attempts to clarify the balance that is struck between these two ideals, using a case study approach of fanfiction and the fair dealing exceptions such as parody or pastiche. Clarity in this area was vital during a lockdown, when more cultural interactions were undertaken online, and standard methods of income generation were blocked to creators. This article analyses the fair dealing exceptions as they stand in UK law after the recent Pelham/Funke Median cases, and suggests a potential test for the pastiche exception in UK law in s30A CDPA 1988. [ABSTRACT FROM AUTHOR]

The rapid expansion of franchising requires that the courts, and the law in general, adapt to new circumstances, including the franchise parties' rightful expectations. Franchisees and franchisors may not act in the spirit of the contract, and the traditional approach under contract damages law often fails to remedy that situation. For example, how can a franchisee or franchisor recover in the event of actions that are not prohibited by the contract, but that nevertheless run counter to a party's natural (and probable) expectations? These and other issues are addressed in the context of a "Fairness in Franchising" rule. Currently, remedies for disgruntled parties to franchise agreements are limited to those available for the breach of an express contract provision, and they certainly do not allow for an award of punitive damages. However, legal remedies for bad faith in franchising agreements already exist. For example, at common law, tort damages may be awarded in a cause of action for "bad faith." The allowance of a tort cause of action for bad faith could deter wrongful acts by parties inducing franchise purchases, by would-be fraudsters (whether franchisors or franchisees) throughout the course of a franchise relationship, and otherwise by free-riding franchisees or through the opportunistic behaviors on the part of franchisors after an agreement has been executed. A standard test for franchising good faith and fair dealing will leave courts better able to not simply deal with bad acts, but also to encourage the franchise parties' appropriate and mutually beneficial actions while they are reaching and then implementing their contracts. [ABSTRACT FROM AUTHOR]

This paper is focused on openness movement and the principles that said movement declared regarding the use of works set under copyright protection to enable for open access works. The three-step-test legal edifice is deeply rooted in international copyright law; its meaning and application is of vital importance for any consideration of amending copyright law with the aim to include provisions for openness. Unless a provision for openness passes the three-step-test there can be no sustainable amendment of copyright law in favour of openness. [ABSTRACT FROM AUTHOR]

This article asks whether the catastrophic impact of the COVID-19 pandemic justifies new limitations or interventions in copyright law so that UK educational institutions can continue to serve the needs of their students. It describes the existing copyright landscape and suggests ways in which institutions can rely on exceptions in the Copyright, Designs and Patents Act 1988 (CDPA), including fair dealing and the exemption for lending by educational establishments. It then considers the viability of other solutions. It argues that issues caused by the pandemic would not enliven a public interest defence to copyright infringement (to the extent this still exists in UK law) but may be relevant to remedies. It also argues that compulsory licensing, while permissible under international copyright law, would not be a desirable intervention, but that legislative expansion to the existing exceptions, in order to encourage voluntary collective licensing, has a number of attractions. It concludes by observing that the pandemic highlights issues with the prevailing model for academic publishing and asks whether COVID may encourage universities to embrace in-house and open access publishing more swiftly and for an even greater body of material. [ABSTRACT FROM AUTHOR]

Intellectual property rights are very important rights that help in the economic development of a country by promoting healthy competition and encouraging industrial development. How IPR is used as a tool in legal research is significant to note. Research is a systemized effort to gain new knowledge. Legal communication via writings shall manifest higher moral values; shall maintain high degree of competence discipline. Legal research inculcates necessary theoretical and practical skills to deal with the diverse and expanding world of law, change and satisfaction. So, the issues that will arise during legal research and the challenges faced by the researchers during the period of research is discussed in this article. This article basically elaborates copyright related issues and challenges during legal research writing. It also specifies provisions for infringement of copyright and rules relating to plagiarism. Hence, present study furnishes a brief overview of intellectual property rights with special reference on research in law. [ABSTRACT FROM AUTHOR]

The development of artificial intelligence draws heavily on training data which may be comprised of copyright works. Utilization of copyright works as such raises questions on copyright infringement as well as the possibilities of the usage being excused under the existing law. There are also concerns with respect to accessing copyright works in digital formats that are commonly protected by digital rights management tools. Restrictions on such usage may hamper the research and development of artificial intelligence applications. This paper examines the said issues with specific focus on first, the applicability of a seemingly Americanized fair dealing exception to copyright infringement under the Malaysian Copyright Act 1987; and second, the exceptions to legal protection of digital rights management. In doing so, the paper studies the existing models of the United States, United Kingdom, and the European Union. It ends with suggestions as to how copyright law may respond to the emerging needs and provide adequate latitude with the aim to promote research and development of artificial intelligence which would ultimately benefit the public at large. [ABSTRACT FROM AUTHOR]

Although sport, in its myriad forms, represent a major pillar of Caribbean societies, sports broadcasters have suffered tremendous loss over the years as a result of signal piracy. With the increasing recognition of the value of broadcast rights in generating much-needed revenue, and the commensurate increased awareness among broadcasters as to how the law may protect these rights, sports broadcasters in the Caribbean have, in the recent years, become a lot more adversarial in their dealings with infringers of their copyright in broadcasts. This has culminated in a recent decision, Television Jamaica v CVM, in which a Caribbean superior court has, for the first time, delivered a landmark judgment on the scope of copyright protection in sports broadcasts. The decision is timely, well-reasoned and progressive, and address a number of nuanced questions, which previously remained unanswered. By drawing on regional copyright legislation, jurisprudence from other jurisdictions, and the recently decided TVJ v CVM case, this article argues that, for the first time, broadcasters in the Caribbean are afforded an adequate and effective level of protection against infringement of their broadcasts, albeit that they cannot claim a monopoly in said broadcasts, since the fair dealing defence has been construed as balancing the rights and interests of competing stakeholders in the field of sport.

Copyright in Canada is subject to a number of statutory defences, of which parodies and non-commercial user-generated content (UGC) are but two examples. However, the interface between these defences and the protection of moral rights is not very clearly delineated in Canada’s Copyright Act. The statutory defences appear to immunise a user from liability for traditional copyright infringement but not from claims of moral rights infringement. Under this fragmentary approach, users engaging in acts of fair dealing or in the production of non-commercial UGC might still find themselves vulnerable to attack from author-claimants alleging that their moral rights have been violated. Through a comparative survey of key legislative provisions in Canada and the United Kingdom, this article explores the extent to which Canada can learn from the UK experience, and considers the viability of streamlining the scope of the statutory defences to copyright infringement, in order to clarify the interface between users’ rights, moral rights and economic rights.

Although sports, in its myriad forms, represent a major pillar of Caribbean societies, sports broadcasters have suffered tremendous loss over the years as a result of signal piracy. With the increasing recognition of the value of broadcast rights in generating much-needed revenue, and the commensurate increased awareness among broadcasters as to how the law may protect these rights, sports broadcasters in the Caribbean have, in the recent years, become a lot more adversarial in their dealings with infringers of their copyright in broadcasts. This has culminated in a recent decision, Television Jamaica v CVM, in which a Caribbean superior court has, for the first time, delivered a landmark judgement on the scope of copyright protection in sports broadcasts. The decision is timely, well-reasoned and progressive, and addresses a number of nuanced questions, which previously remained unanswered. By drawing on regional copyright legislation, jurisprudence from other jurisdictions and the recently decided TVJ v CVM case, this article argues that, for the first time, broadcasters in the Caribbean are afforded an adequate and effective level of protection against infringement of their broadcasts, albeit that they cannot claim a monopoly in said broadcasts, since the fair dealing defence has been construed as balancing the rights and interests of competing stakeholders in the field of sports. [ABSTRACT FROM AUTHOR]

This article asks whether the catastrophic impact of the COVID-19 pandemic justifies new limitations or interventions in copyright law so that UK educational institutions can continue to serve the needs of their students. It describes the existing copyright landscape and suggests ways in which institutions can rely on exceptions in the Copyright, Designs and Patents Act 1988 (CDPA), including fair dealing and the exemption for lending by educational establishments. It then considers the viability of other solutions. It argues that issues caused by the pandemic would not enliven a public interest defence to copyright infringement (to the extent this still exists in UK law) but may be relevant to remedies. It also argues that compulsory licensing, while permissible under international copyright law, would not be a desirable intervention, but that legislative expansion to the existing exceptions, in order to encourage voluntary collective licensing, has a number of attractions. It concludes by observing that the pandemic highlights issues with the prevailing model for academic publishing and asks whether COVID may encourage universities to embrace in-house and open access publishing more swiftly and for an even greater body of material. [ABSTRACT FROM AUTHOR]

Copyright of Revista de Direitos Fundamentais & Democracia is the property of Revista de Direitos Fundamentais & Democracia and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Information about the acceptance by Canadian Higher Education Institutions (HEI) of the Access Copyright (AC) tariff is important for educators even though only a minority of HEIs in Canada have committed to the AC tariff. In addition, the copyright “pentalogy,” the five major decisions of the Supreme Court of Canada (SCC), and its interpretation of fair dealing has become relevant for the institutions, faculty and students. Many universities and community colleges in Canada have adopted the Universities Canada (UC) guidelines on fair dealing, while some have adopted the “six-point test” as their guideline. In some cases, institutions have not adopted any policy or guidelines on any aspect of copyright. This paper will investigate these issues to provide one view of the behaviour Canadian HEIs exhibit in their adherence to AC and their use of policy and guidelines at their institutions.

Copyright’s interest in promoting creative production is often described as requiring a “balance” between exclusion and access rights. Owners of copyright receive exclusive rights to control copies of their works, which enables authors to earn returns on their creations through sales or licensing transactions. But as important to promoting creation are the user rights in copyright law which permit building on the work of predecessors. The necessity for balance in order to promote creation is clearly evident in the documentary film industry, where producers rely on copyright ownership to facilitate the dissemination of their works through broadcasters and other distributors, and on user rights to incorporate excerpts of other copyrighted material in their work. This article draws on a collaborative South African research project that has been working since 2008 to document influences of copyright law on the production of documentary films. The results of that research, summarised in the first part of the article, show that South African filmmakers are hampered by a legal environment that denies them copyright ownership in the majority of their projects while also denying them adequate rights to use, in their own works, elements of the works of others. The second part of the article describes capacity-building approaches and legal reforms that could be advantageous to the local film industry.

The issue of educational use exceptions under copyright law has been a contentious issue in India for several decades. The decision of the Delhi High Court in the lawsuit filed by publishers against Delhi University and the Rameshwari photocopy shop is viewed as a significant victory in favour of the educational use exception contained in the Copyright Act. This judgement is however silent on certain compulsory licencing provisions that were specifically inserted into Indian law to deal with the educational requirements of India. These provisions were meant to deal specifically with the requirement of using copyrighted work for educational content. For reasons not clear, the Delhi High Court judgement did not consider these legislative provisions while interpreting the Copyright Act. For this reason alone, it is possible to argue that the judgement of the Delhi High Court is per incuriam. [ABSTRACT FROM AUTHOR]

Highlights • As copyright expands and extends, exceptions and limitations are ever more important for creativity and innovation. • Creators spend extra time, money to make work; avoid/abandon work because of copyright; avoid imagining work that uses copyrighted materials. • Australian creators were surveyed about about copyright exceptions in relation to their creative practice. • Further research can probe these costs further, if government-authorized entities are required to divulge information about rights payments. • Copyright debate in Australia and elsewhere must consider costs of narrow exceptions in the creative process, because it affects future culture. Abstract The kind and extent of exceptions and limitations to copyright monopolies are a major focus of copyright reform discussion worldwide. The debate is often portrayed as pitting the interests of creators against users. Australian copyright law features narrow and limited exceptions. Australian creators benefit from copyright monopolies; but do they suffer any costs for lack of flexible exceptions? A national survey of creators showed that they experience significant costs in time and money in making work; avoid or abandon projects because of copyright problems; and avoid developing ideas for projects that involve use of third-party copyrighted materials. These costs have previously been uncalculated and not included in national policy debate. The results provide information not only for the Australian context but for policy discussion internationally. [ABSTRACT FROM AUTHOR]

This comment considers Global Yellow Pages Ltd v Promedia Directories Pte Ltd, an important decision on copyright in compilation works by the highest appellate court in Singapore in 2017 which rejects the "sweat of the brow " approach, following developments in the US, Europe and Australia. It also considers the applicability of the American fair use defence, in particular the transformative use doctrine, to Singapore. [ABSTRACT FROM AUTHOR]

The article examines the potential role that copyright law might play in protecting personal images that are uploaded and shared on social networks. The article considers the way in which copyright protects personal images that are uploaded online. To do this, it considers the interests that arise between creators and subjects when an image is created. In particular, it will be shown that copyright law provides some protection; however, this protection is limited. [ABSTRACT FROM AUTHOR]