Q: What's the difference between Australian and United States copyright law?

A: The key differences between Australian and United States copyright law are primarily found in the scope and interpretation of fair use, as well as the duration of copyright protection.

In the United States, copyright law provides a broad "fair use" doctrine, which allows for the use of copyrighted material without permission for purposes such as criticism, comment, news reporting, teaching, scholarship, or research. This doctrine is quite flexible and considers factors like the purpose and character of the use, the nature of the copyrighted work, the amount and substantiality of the portion used, and the effect of the use on the market for the copyrighted work.

Australian copyright law, on the other hand, does not have a general fair use provision. Instead, it uses a more limited "fair dealing" concept, which allows use of copyrighted material only for specific purposes like research and study, criticism or review, news reporting, legal advice, and parody or satire. This makes the Australian system less flexible compared to the U.S. fair use doctrine.

Additionally, the duration of copyright protection differs slightly. In the U.S., copyright generally lasts for the life of the author plus 70 years, while in Australia, it lasts for the life of the author plus 70 years for literary, dramatic, musical, and artistic works, but there are variations for other types of works.

It's important to understand these differences, especially if you're dealing with works that might be protected under both Australian and U.S. copyright laws. Navigating these legal frameworks can be complex, and it's wise to seek legal advice if you're uncertain about how these laws apply to your specific situation. Remember, respecting copyright law is crucial to avoid legal disputes and to protect the rights of creators.