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RIDA 278 | 10-2023

Doctrine

Acknowledgement of the right of works system: a system situated between copyright and authors’ rights

DAI, Zhe

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Résumé :

In addition to copyright, there is a special system called the droit d'œuvre system. But this system has not been known outside the country of droit d'œuvre. It originated in Japan and was later adopted by mainland China, Taiwan, South Korea and North Korea. Its rules are derived from the transplantation of the rules of copyright and author's rights. However, legislators have made numerous special provisions, so that the droit d'œuvre system is not equal to copyright. As a result, droit d'œuvre has become a special system. It is therefore necessary to recognize the independent status of this system.