- From: Adrian Pohl <pohl@hbz-nrw.de>
- Date: Tue, 22 Mar 2011 10:08:26 +0100
- To: <public-lld@w3.org>
Hello, I think Owen gives a very good overview about intellectual property rights on data (bases) in Europe. I especially agree with the "two areas of uncertainty" Owen mentions. Regarding Creative Commons licenses and data bases: I was quite disturbed when CC published a post which made clear that their licenses are also appropriate for data[1] as the OKFN always advised against CC licenses (except CC0) for data and data bases. I expressed my uncertainty on the od-discuss list and Rufus Pollock provided a clear answer, see [2]. Adrian [1] http://creativecommons.org/weblog/entry/26283 [2] http://lists.okfn.org/pipermail/od-discuss/2011-February/000031.html >>>Owen Stephens <owen@ostephens.com> schrieb am Freitag, 18. März 2011 um 15:00: > I don't claim any legal expertise but here is my take on the rights conveyed > in the EU directive mentioned by Simon - this is more to generate discussion > than an attempt to be definitive - so please challenge anything that doesn't > look right! > > *COPYRIGHT* > > Under Directive 96/9/EC of the European Parliament and of the Council of 11 > March 1996, databases can be protected by copyright in EU member states. > This right applies to databases which: > > "by reason of the selection or arrangement of their contents, constitute the > author's own intellectual creation" (Article 3 of > http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31996L0009:EN:HTM > L > ) > > While there are no hard and fast tests for 'originality', a clear example of > a database not considered worthy of Copyright protection is Television > Listings (see > http://ec.europa.eu/internal_market/copyright/docs/databases/evaluation_repo > rt_en.pdf > - > page 8, which in turn references "Judgment of 6 April 1995, Radio Telefis > Eireann (RTE) and Independent Television Publications Ltd (ITP) v. > Commission of the European Communities, Joined cases C-241/91 P and C-242/91 > P)". > > The current interpretation in Wikipedia suggests further than no database > which aims to be 'complete' ("that is where the entries are selected by > objective criteria") would qualify as "the author's own intellectual > creation" (http://en.wikipedia.org/wiki/Database_Directive). > > While I'm not sure the statement from Wikipedia is accurate it would seem > unlikely that most databases of bibliographic data would be seen as > 'original' in the sense of the directive. > > *SUI GENERIS DATABASE RIGHT* > > As well as covering copyright in databases, Directive 96/9/EC also > establishes a 'sui generis database right'. This provides a right: > > "for the maker of a database which shows that there has been qualitatively > and/or quantitatively a substantial investment in either the obtaining, > verification or presentation of the contents to prevent extraction and/or > re-utilization of the whole or of a substantial part, evaluated > qualitatively and/or quantitatively, of the contents of that database." ( > http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31996L0009:EN:HTM > L > ) > > Colloquially this is a 'sweat of the brow' right - essentially this is > saying if creating the database had a cost (i.e. some signficant effort was > involved), the database is automatically protected by the database right > which prevents another party copying all, or a substantial part of the > database. The Television Listing example above is one that would not be > protected by Copyright, but would be protected by this Sui Generis Database > Right. > > It is highly likely that any substantial data sets we are dealing with > within Lucero are protected by the Sui Generis Database right, although very > small data sets might be excluded. Certainly we could be pretty sure that > the library catalogue would protected in this way. > > The Database right applies for only 15 years from the completion OR first > publication of the database. However, where a database is published, any > significant update to the database (whether through a single action, or > ongoing changes) refresh the term of the database right, starting at 15 > years again (see 'Term of Protection' in > http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31996L0009:EN:HTM > L > ) > > The main two areas of uncertainty (IMO) are: > > - What might constitute a 'substantial part' of a database > - What might constitute a 'significant update' of a database in order to > refresh the 15 year term of the database right > > It seems likely to me that case law will provide the only route of > establishing guidance on these issues > > Finally just to note that from v3.0 the CC licenses include provision for > both works protected by copyright AND works protected by the EU Sui Generis > Database Right (see > http://wiki.creativecommons.org/images/f/f6/V3_Database_Rights.pdf). > Therefore as far as I can see it is valid to apply CC licenses to > bibliographic datasets, and the outcome is essentially the same whether the > dataset is protected by Copyright or by both Copyright and Database Right > > > Owen > > > On Fri, Mar 18, 2011 at 10:42 AM, Jodi Schneider > <jodi.schneider@deri.org>wrote: > >> Well-said, Simon! I suggest that we crib from what you've written for our >> report. Do you mind? >> >> To that end, I've pasted your comments into the Talk page of our Draft >> issues wiki page: >> >> > http://www.w3.org/2005/Incubator/lld/wiki/Talk:Draft_issues_page#Simon_Spero. > 27s_comments_on_US_rights.2Flicensing_issues >> >> >> > <http://www.w3.org/2005/Incubator/lld/wiki/Talk:Draft_issues_page#Simon_Spero. > 27s_comments_on_US_rights.2Flicensing_issues> >> -Jodi >> >> On 17 Mar 2011, at 20:09, Simon Spero wrote: >> <trim> >> >> >>> http://liber.library.uu.nl/publish/issues/2010-3_4/index.html?000512 >>> >> It is important to note that the cited article is published in LIBER : The >> Journal of European Research Libraries. >> >> The article states that "The content of a data base is protected by >> copyright when its producer can prove that he has made substantial >> investments to create and maintain the database (financial, technical and >> human resources)." (Bérard 2011, p. 326) >> >> This statement is correct within the EU, as a result of a specific EU >> directive (EC 1996), which granted a sui generis copyright in databases >> under the sweat-of-the-brow theory. >> >> This statement is not correct as a statement of US law. Copyright on the >> basis of Sweat-of-the-brow was rejected by the United States Supreme Court >> in Feist Publications, Inc., v. Rural Telephone Service Co., 499 U.S. 340 >> (1991) <http://www.law.cornell.edu/copyright/cases/499_US_340.htm>. >> >> In summary, the 1976 revisions to the Copyright Act leave no doubt that >> originality, not "sweat of the brow," is the touchstone of copyright >> protection in directories and other fact-based works. Nor is there any doubt >> that the same was true under the 1909 Act. The 1976 revisions were a direct >> response to the Copyright Office's concern that many lower courts had >> misconstrued this basic principle, and Congress emphasized repeatedly that >> the purpose of the revisions was to clarify, not change, existing law. The >> revisions explain with painstaking clarity that copyright requires >> originality, § 102(a); that facts are never original, § 102(b); that the >> copyright in a compilation does not extend to the facts it contains, § >> 103(b); and that a compilation is copyrightable only to the extent that it >> features an original selection, coordination, or arrangement, § 101. >> (*Feist v. Rural, supra)* >> >> >> The claim and grant of copyright in OCLC's database were made in 1982 and >> 1984 respectively, prior to the decision in Feist. As Brown (1985) makes >> clear, OCLC's claim was based on "sweat of the brow". It is thus >> questionable the 1984 copyright grant survived that decision. >> >> It is possible to assert property rights in databases through licensing >> contracts; OCLC's guidelines and contracts do constrain certain uses, but >> explicitly exempt "online access provided to end-user patrons of a library >> in authorized possession of the records". Guidelines §II.6. >> >> This exemption was not present in the proposed revisions to the usage >> guidelines; however, since these controls are a matter of contract rather >> than copyright, applying revised guidelines would require requiring >> libraries to impose similar restrictions on all patrons accessing their >> catalogs, since contracts are only binding on the parties privy to those >> contracts. >> >> OCLC has made no statements against interest that I am aware of in regards >> to this issue. >> >> Senior management at OCLC has directly stated that they consider >> maintaining and supporting both Worldcat and DDC to be a duty to the >> community, and that if there were an open, distributed platform for >> maintaining those databases, that would not *reduce availability, >> reliability, and data quality, *they would be more than willing to pass >> on the burden. Since the copyright in DDC is unquestionably valid (AMERICAN >> DENT. ASSN. v. DELTA DEN. PLANS ASSN., 126 F.3d 977 (7th Cir. > 1997)<http://www.law.cornell.edu/copyright/cases/126_F3d_977.htm>, >> bringing up both products in the same breath indicates that the availability >> of copyright is not the deciding factor. >> >> I am not a lawyer, nor did I stay at a Holiday Inn Express last night. >> >> Simon // IMHO, The proper purpose of OCLC is to fund OCLC Research :-P >> >> Bérard, Raymond (2011). "Free Library > Data?<http://liber.library.uu.nl/publish/issues/2010-3_4/index.html?000512>". >> Liber 20.3/4. >> >> Brown, Rowland C. (1985). “OCLC, Copyright, and Access to Information: Some >> Thoughts”.: Journal of Academic Librarianship 11.4. P. 197. >> >> EC (1996). Directive 96/9/EC of the European Parliament and of the Council >> of 11 March 1996 on the legal protection of > databases<http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31996L > 0009:EN:HTML>. >> >> >> >> >> >>
Received on Tuesday, 22 March 2011 09:09:26 UTC