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62nd IFLA General Conference - Conference Proceedings - August 25-31, 1996

Pre-Conference Workshop on Copyright

Director General Helge M. Sønneland
Norwegian Ministry of Cultural Affairs

PAPER

Paper presented at the IFLA pre-seminar, Tianjin, China, August 22. 1996

Introductory remarks

I have been asked to give an introduction to copyright, the philosophy behind it, its history and development, its importance to the library world,the nature of the law of copyright and how it has been implemented in different countries and cultures.

I was honored to be asked and I am very pleased to be able to discuss copyright questions with you at this seminar, although I must admit that the task given to me is not only overwhelming, but impossible to fulfill in a presentation of less than an hour, if the aim is to give you anything more than a broad overview and some basic ideas.

You will therefore certainly understand that I will not go into detailed discussions.We shall have ample time to do so on specific issues during the seminar. Furthermore, I will take a pragmatic view, the view of a practitioner more than that of a scholar. My own background is that of a civil servant, dealing with copyright from a practical as well as from a legislative point of departure.

Regard then my introduction also as a form of advertisement, the aim being to convince you- if you are not already convinced -, that this is a fascinating field of law with direct and concrete consequenses for you -both as professionals and as citizens of national and international societies which are now described as "information societies". Admittedly, copyright questions have not attached ver y much public and political attention in the countries I know of. The reasons for this are many - one being that this is a very complex - some say esoteric -field of law - another is that the language used by us lawyers and experts tends to be exclusive rather than inclusive,to put it mildly. But the questions involved surely affect not only professionals,and they may hopefully attract wider inte rest in the near future.

My first thesis is: Copyright legislation, nationally and internationally, is of the utmost importance to the library world, because all the main library activities and operations in all types of libraries depend on this legislation.I therefore note with great pleasure that both IFLA and a number of national library associations have engaged themselves more actively in this important field .

My second thesis is that copyright legislation is perhaps the most important field of law in the cultural field, as it concerns directly and indirectly cultural life in any given country.

What is copyright ?

Copyright may be seen as the regulation linking the world of ideas to the world of commerce, as the legal mechanism for the ordering of cultural and social life.

This field of legislation has vast economic implications , not only for the parties directly involved, but for international trade.The revolutionary developments of new technologies, enabling new ways of disseminating information in digital form, be it knowledge, entertainment or computer programs - have led copyright into an era of constant review and revision both nationally, regionally and in ternationally, as we shall see during this seminar, involving a multitude of interested parties seeking to influence the process. The library world has to position itself in this context.Although the history of copyright and the developments in this field have, as we shall see, always been closely connected to new technologies allowing new forms of use, the economic and international aspects of new technologies have perhaps never been more acute than at present. The last two decades have shown an intense legislative activity in many countries - caused partly by political changes, but also by the need to keep pace with new realities. Copyright legislation tries to answer the question: How best to reconcile the partly shared, partly contradictory interests of authors who give expression t o ideas, publishers who disseminate ideas, and members of the public who use the ideas.

An easy answer would be: copyright is basically the individual right of an author to control the exploitation of his work, and dispose of it in return for remuneration. But this is only the starting point of our exercise.

For our purpose at this stage, I shall use a broad and pragmatic approach,and define copyright as the set of rules and regulations that in a given country defines the scope of rights in a work or a performance. Taken in this broad sense, copyright legislation will define who has which rights, for how long a period of time, the limitations to those rights, and the regulations concerning transfer and enforcement of those rights. It encompasses not only the rights of the original author, but also of the sucessors in title, and what in some legal systems are called "neighbouring rights" - the rights of producers and performers and of broadcasting institutions.I shall use the term "author" as covering both the person who creates a work and -if the legislation so permits - the legal entity t o which copyright is bestowed.

You will have noticed that in this legal field many expressions have a different meaning from that in the ordinary language,for example the expression "work", as the object of protection, "author" as the beneficiary of the protection, and " publisher" as the user of protected works.

Works are intellectual creations in the fields of literature, music, art and science. To qualify for protection, the work must be an original creation. It is for the courts to decide whether a sufficient degree of originality exists for a creation to obtain protection. The situation here is different in different countries.We shall revert to this, but let us observe that the notion of "work" has acquired a very wide interpretation

When you ask what kind of works are given protection, you will find a wide variety.In most legislation you will find non-exhaustive lists of examples, and you will find that "literary works" encompasses not only books and other writings, but also - among others - computer programs. In the development of copyright, the crucial question has often been exactly that: How to treat new modes of exploit ation and new types of "works", for example phonograms, cinematographic pictures, computer programs, data bases etc. As technology continues to offer new types of "works" and new forms of exploitation, this will continue to be the focus of the debate. Should they be regarded as works, or treated in other ways?

Most national legislators will, when passing laws in this field, be bound by international instruments, conventions. As we shall discuss in greater detail later in this seminar, copyright is indeed an international field , and most states are parties to one or more international conventions. These conventions give a framework, within which the legislator has to operate.This is why those intereste d in the development of copyright have to familiarize themselves not only with the national debate, but also with the international development and discussion, leading to reframing of the conventions and thereby altering the national obligations and national framework for the copyright legislation.As the international process is slow,you will observe that national legislations have often found di fferent answers to the questions, and when government representatives sit down at the negotiating table, they find it difficult to reconcile different approaches. We will revert also to this theme. It is important, when discussing these matters, to distinguish between the author or rightholder, between the the work itself and copies of the work. It is also important to remember that what is protected is the expression of an idea, not the idea itself. Neither the basic plot of Romeo and Juliet, nor the instructions how to operate your CD-player can be allowed to be monopolized through co pyright protection. But the individual play and the individual instruction manual are protected.

The work itself is immaterial and the exploitation can, as we know, take many forms . In any given work, therefore, there can be many rights: i.e. the right to copy,to translate, to lend or rent,the right to perform,the right to adapt. At the outset, copyright gives the author an exclusive right to control the exploitation of the work, by making copies of it, or by making it available to the public in any form. Protection of the work is in most countries not dependent on the existence of the work being fixed in tangible format; in most cases the work is protected when created. But some countries require some formalities as a prerequisite for protection and some require registration, either to obtain protection at all or in order for the rightholder to enforce his rights .
Against this background let us only note that the mere possession of a copy of a work - i.e. a book - does not give the holder of that copy any copyright.

But let us also take note ,already at this stage, that when an author makes the work available to the public, he or she also takes the important step to put the work into the public sphere: From that point in time the copyright legislation will not only define the author's exclusive rights. It will also define the scope of the protection in this sphere, and the limitations to it.

As we shall see, the protection may be limited not only in time, but also in scope.When the work is published or otherwise made available to the public, the law defines what rights to that work shall be given to the users,the consumers, and the public at large - and the libraries. One line of thought sees any right given to users as exceptions to the exclusive right, which deserve special and good reason. Another - to which I belong - rejects the existence of an a priori principle of "unlimited exclusive right", and regards the limitations to the exclusive right not as secondary to the author's rights, but as founded in their own right.

Exclusive rights can be limited not only by regulations stating that the public have free access to certain uses, like private copying, but also by stating that the use is allowed when a remuneration is paid . These types of limitation are called legal licences,or statutory licences.

The legislative debate, therefore, in any event is a debate on which rights should be the author's exclusive rights, - the right to say yes or no to a specific use,and eventually to set the conditions for that use - and on defining the situations where the work can be used against payment,or freely by the public.An important example is the debate on the borderlines of "fair use" or "private use" .

The copyright debate, as I see it, is a debate focused on how and where to find the equilibrium between the involved parties : The authors, the producers, the different kinds of (other) users, and society at large.

HISTORY AND BACKGROUND

"Everyone has the right to protection of the moral and material interests resulting from any scientific,literary or artistic production of which he is the author."

Also, in the UN charter on social, political and cultural rights, copyright is included.

But seen in the light of history, copyright is a fairly new invention and it has developed very much as a result of technological changes. It is a Western invention , but is has shown itself flexible enough to be adopted in most cultures and socio-economic systems over the years.

Many intriguing debates have been held in scientific circles on the roots of copyright, seemingly often on the assumption - or in the hope - that the older the roots can be proven to be, the better the defence of this legislation.

As early as in ancient Greece and Rome we find notions that are now incorporated in copyright, namely the moral condemnation of issuing another persons work as one's own; plagiarism.

The need for regulations in this field was first felt after Gutenberg in 1436 made it possible to make a multitude of copies by printing. (Seperate printing characters were known in China already in the year 11oo). Book printers became publishers, and they soon discovered that unauthorized copies were disseminated, to the detriment of their business.

Printers' piracy was only one reason for attracting the government's attention. Others were, as Edward Ploman and L Clarc Hamilton put it, the following three concerns: the spread of knowledge,greed and control. The relative weight of each concern differed over time.

A system of privileges, limited monopolies, developed. A primary example is found in England, where the Stationer's company was given exclusive right to print and sell books. The intention at this stage was to protect the publisher's investments. But it was also a way of trying to control the content of what was printed; In order to print, it was necessary to obtain a licence - and to declare tha t the material was within the limitations set by the authorities.This pattern existed in Europe for the next three centuries.

Slowly, during the seventeetnh and eighteenth century, the concept of "intellectual property" was formalized. Two prerequisites were at hand, firstly, societies with a tradition of individual creation and art, where the goal of an artist was to attain recognition and fame, and the other; the industrial revolution, with the concept of immaterial rights of intellectual property that could be bough t and sold.

The first copyright legislation was adopted in England by the statute of Queen Anne in 1709, where for the first time the author's right to control the printing of the work was aknowledged. The right to print was given for a period of 14 years and could, if the author was alive, be renewed for another 14 year period, and the works already in print were given 21 years of protection.The Statute wa s a property right, a protection against piracy. The moral rights of the author were not mentioned. The moral rights are - the right of the author to protect his integrity, to protest against mutilation of the work, and to be acknowledged as the author.

During the 18th century, copyright was introduced into legislation throughout the world - the US Constitution in 1789 stated that " The Congress shall have the power .. to promote the progress of science and useful arts, by securing for limited time to authors and inventors the exclusive right to their respective writings and discoveries". The first federal copyright law was passed in 1790.

The Anglo-American concept, as it evolved, was an exclusive economic or property right of the author to reproduce his work for a limited period of time. This right could be sold - and the buyer was free to exploit the work. And to change it.

In Europe John Locke had postulated, in 1690, the theory of an intellectual right for the author, taking as the basis the effort that the author expended in the creation of the work. The author's right was not created by law but existed in the legal consciousness of man - it was a part of natural law.

In France, the spirit of the natural rights theory resulted in a legislation which took onboard the concept of author's rights. After the revolution, two decrees were given; one in 1791 regognizing the right to public performance, and the other in 1793 giving the right to copy and reproduce.

Thus the ideological foundation and the reasons behind the legislation, were manifold: The legislator felt it right that the creator should be able to enjoy the fruits of his or her work; that the copyright legislation should foster creativity and development of knowledge. But also this legislation should enable the publisher to protect his investments. Basically, this reasoning has not changed dramatically over the years.You will find different schools of thought concerning how far the basic ideology will give you answers to the questions raised by new technology: To what extent should rightholders be able to control - and/or be remunerated - for new uses of works and performances opened to us? The majority will accept, I feel, that new use should also be to the benefit of the authors .

The development of copyright took somewhat different routes in different countries.In the mid- 18th century it became clear that copyright should be limited in time, and the type of works receiving protection was enlarged. Not only literary works, but also works of art, drama and music were protected and performance rights were included, as we saw in the decrees after the French revolution.

But even more important was the differentiation in development in the countries with a common law tradition and the countries with civil law traditions, the former focusing on the economic rights, the latter also enshrining the moral interests of the author.

During the 19th century the development of copyright, especially in the civil law countries, was strongly influenced by natural law, stressing the link between the author and his work. The work is seen as a reflection of the author's personality, and consequently the claim for protection of the authors moral rights gained strength: The author should have a right not only to control the use of the work, but also to protect his own integrity and the integrity of the work, and to demand patronage of the work. But it is only in our century that the moral rights have been included in the legislation of many countries. The division in concepts between the civil law countries of the world and the common law countries has been maintained, primarily based on the different ideological basis. We sh all take a closer look at this later. But let us note at this stage that the differences should not be exaggerated, although they are very notably present in today's copyright discussions.

The diversities between common law and civil law countries

The development of copyright has, when we look upon it today, divided the world into two different copyright traditions. Broadly speaking, the common law countries - (the Anglo-American tradition) on the the one side give the protection to the work and focus on the economic rights, whereas the civil law countries put the author in the first place.

This picture is in no way clearcut, as we shall see: When a comparison is made, national differences within the two "camps" are also many, and within the group of common law countries we find that some, like the United Kingdom, should perhaps better be placed in a middle position.

Let me mention some of the differences:

Standards of protection. The two systems seems to differ concerning the level of originality needed to obtain protection. As a main rule, one can say that protection is provided in the common law countries when the work originates from the author and is not copied ("all wich is worth copying is protected")- one test being "the sweat of the brow". If we speak in broad terms, this seems to be t he general impression, although there are nuances in the picture following recent court decisions in some countries. In the civil law countries a degree of creativity, reflecting the individuality of the author's personality, is required. But even here, nuances are found in recent European Community legislation, e.g. on protection of databases, taking "orginality" as the sole criterion.
Formalities. The civil law countries gave protection without any formalities:the protection was granted once the work was created. In common law countries, protection was only granted if certain formalities were followed. Best known is the former US requirement, where the "copyright -sign" - the C within a ring - together with the name of the author and the year and place of publishing was a lways enough to obtain protection, but where registration of the work also was a necessity to enforce the rights upon infringers.
Formal requirements are rarely found nowadays, since the major common law countries have done away with them.
Ownership. In accordance with the ideological point of departure found in natural law, the civil law countries as a main rule accept only natural persons as authors.Common law countries accept also legal entities as authors, like film and phonogram producers and broadcasters. In common law countries ,the copyright can also be vested directly with the employer, in the socalled "work for hire " .
On the other hand, in the civil law countries we often find examples of so called "legal presumptions", that is: unless otherwise provided for in contracts between the parties, the rights are presumed transferred , for example to the film producer.
Within the civil law countries, there is differentiation concerning which rights are usually presumed transferred from the author to the publisher or producer: Since there are many rights in a given work, and they can be divided, some laws have a principle of specification, that is: Only those rights and uses known at the time of contract are transferred, and often it is seen that the author m aintains some rights in his own hand, i.e. reprographic rights. The situation in civil law countries is therefore - as a result - often very complicated when it comes to clearance of rights for new forms of use, wheras in most common law countries the producers have obtained all rights -even for unknown uses.
An example was the advent of video, where the rights to distribute the films on cassettes had to be negotiated in most civil rights countries, wheras they were included f.ex. in USA. I shall revert to this, as it is one of the challenges for the European encounter with cyberspace.
Moral rights. The pre-eminence of the authors rights,and the subsequent acceptance of his moral rights, represent another dividing line. But again the clearness of the division is somewhat blurred. The law of the United Kingdom has given protection to moral rights and in the United States of America these rights can be found, if not in federal legislation, in common law and in state statutes. The level of moral rights protection in common law countries is heavily debated.
Related rights- neighbouring rights. As technology presented mankind with new modes of exploitation of works, new groups of users of work claimed protection: Record producers, film producers, broadcasters. Also performers had good arguments
How these parties are treated concerning protection differs not only between different countries - but primarily between the two categories. Common law countries have often included them among authors and provided copyright, whereas civil law countries have strongly objected to this, and have provided them with what is called neighbouring rights.
The concrete results, though, do not always differ. Wherever the protection is provided for, the substantial answer to the question which rights should be given to whom is the important matter. In actual life, the bargaining power between for instance actors or musicians on one side and producers on the other are defined through the answers given, and the level of protection given to these groups differs widely throughout the world.

The above observations, sketching the differences, give an indication of the present task in the ongoing international debates, namely to bridge the gaps- and agree at least in real terms, if not in ideological terms, between the systems.

International development

Ideas know no boundaries and we all experience what is now obvious, namely that works of literature, science and art can be disseminated in ways that make national boundaries obsolete in most cases- although we are familiar with attempts to hinder free flow of information. During the 19th century, the problems caused by the lack of international protection were felt by the authors and publishers , especially in areas sharing the same language on both sides of national borders. Not only were unauthorized copies sold in direct competion to the original rightholder- they were also translated into foreign languages, and the author saw no remuneration.
At first, states entered into bilateral agreements, giving protection on the basis of reciprocity.An international organisation, ALAI, under the patronage of Victor Hugo, proposed international solutions to the problems.In 1886,representatives of 7 states signed a treaty in Berne - and the Berne Convention for the Protection of Literary and Artistic Works was born, already then foreseeing the for mation of a Union between the states ratifying the convention. The ultimate goal - to achieve an international law on copyright - proved to be unrealistic, but the signatories agreed on two main principles: To give the same protection to nationals and works from another signatory state as was provided for in national legislation (socalled national treatment) and to secure the convention's minimum requirements of protection for the nationals and works of other signatory states. (This means that lower protection than the minimum requirements might be given to the national rightholders in a contracting state,but this is rarely seen). These two fundamental principles are the main pillars of the convention ,which over the years has been amended several times. The Berne convention now also giv e protection to the moral rights of the author.
The next speaker will present the convention in detail and also present the ongoing discussions on a new protocol to the convention.The periodic revisions of the text of the convention have tried to catch up with technical developments. Differences in principles and views have, however, continued to this day. Even if solutions have been found some questions have remained unsolved till this day.
In 1952 a Universal copyright convention (UCC) was signed under the auspices of Unesco.This convention is also based on the principle of national treatment, but have fewer minimum requirements ( For example the minimum term of protection is the lifetime of the author and 25 years following the year of his death, 50 years in the Berne Convention). The UCC also accepts formalities.
This convention therefore bridged the gap between the Berne Union members and - at the time - important non-member countries such as USA and the former Soviet Russia. During recent years both USA and Russia have become Berne members - a fact that strongly influences the actual international development, and since common law legislation exists in USA, exercises in my opinion, a stronger impact on international debate.
I shall not go into the questions of the development of copyright in the former socialist countries of Eastern and Central Europe, and former members of the Soviet Union, who are now all members or on the verge of becoming members of the Berne union. It is worth noticing that the number of member countries has risen from about 80 ten years ago to presently 118.
One aspect of the international development deserves special attention, and that is the part caused by the special need of the developing countries to have beneficial access to protected works. For this purpose, a special appendix, called The Protocol on Developing Countries, was formulated to the Bern Convention in 1969 and revised in 1971. Opinions differ whether the industrialized countries we nt far enough in this respect -that is open to judgement. But one important observation to be made is that no country can do without copyright, and that also poor, developing countries in a total perspective must adhere to the international mechanisms, if for no other reason, than to obtain protection for their own cultural creations.
In 1951, the Rome convention for the protection of performers, phonogram producers and broadcasters was opened for signature, and this convention has gained strength over the years. But still only some 5o states have adhered to it, among them many European and LatinAmerican. The protection for performers however - especially in audiovisual performances- is in my opinion too weak and is one of the difficult questions to be resolved.
Other international instruments could also be mentioned, but these fall outside the scope of this introduction.
One late and important development on the international scene should however be mentioned. During the last decades, cultural goods - be they films or records - have become an increasingly more important factor in world trade. Likewise, the advent of micro-computors , and the software to be used with them. The problem of piracy of these products has become an ever larger problem. This is the main background to the fact that in the Uruguay round of the GATT-negotiations (General Agreement on Tariffs and Trade), trade related aspects of intellectual property were included. The result is that the obligations contained in the Berne convention are taken onboard in a special agreement on Trade Related aspects of Intellectual Property Rights (TRIPS) and on some points new obligations are added. Even a few of the rights provided for in the Rome convention are included. Consequently the principles of national treatment and minimum requirements are now the basis line for all the 125 states that signed the new GATT-agreement. The agreement includes another principle well known in trade but not in copyright agreements, that of "Most Favoured Nation" : That is: as a general rule,favours offer ed to one of the contracting states should be given to all - if provisions for exceptions are not provided for. The new World Trade Organization is now in operation, and the copyright obligations came into force 1. January this year. (Some countries have a transition period).
A point to be stressed is that the TRIP's agreement also includes dispute settlement regulations. Such are not found in the Berne convention .This might turn out to be a factor of great significance to the futher development of copyright.

The discussions on the TRIP's obligations were among the most difficult to resolve in the whole Uruguay round, and in the end it was what has been described as a "North- North-negotiation".Without going into detail, let me here only observe the following: Whereas international development in the copyright field up till now sprang mainly from meetings within the Berne Union, the UCC and the Rome C onvention, it remains to be seen which will be the main forum for further development.

Add to this the regional developments, especially in Europe, where the European Union has harmonized its legislation in important areas and thereby agreed on a high level of protection for both authors and holders of neighbouring rights. The term of protection, for example, is prolonged to 70 years p.m.a. This harmonizing process will continue not least with regard to questions relevant to the in formation society and the "electronic highway". This means that those wanting to take part in the ongoing debate must have a watchful eye in many directions. As a participant in many international meetings on these issues, one cannot fail to notice the observers, the lobbyists, the many representatives of parties - attending in ever increasing numbers. I have observed with pleasure that IFLA is regularly present among them and taking the floo r.

Management of rights

When trying to identify lines in the development of copyright, the legislation strictu sensu does not always tell the whole story.

The management of the rights provided for and the system developed in that respect are important factors. We are all acquainted with the impressive organization representing the authors of rights in musical works, where the schemes of "blanket licensing" are found. As the world grows more complicated and the copyright needs fine-tuning to strike the right balance, these mangement organizations- be they licensing organizations or collecting societies- play an ever more important role concerning management and enforcement for many categories of works and rights. Such collective systems can on the one hand simplify life for users, - on the other hand give more strength to the rightholders. - although we should not forget that individual management is still the main picture. (It is my predi ction that the library world will have increased contact with such organizations in the years to come.)

For some uses, especially new forms presented by technology, new systems of remuneration have been introduced in some countries. Levies on reprographic equipment to compensate for reprography is one example, levies on blank video and audio-tapes another.

Some countries have introduced socalled "public lending schemes", giving remuneration to authors for the lending of their books, primarily in public libraries.

Some countries regard this as part of copyright, while some have introduced these schemes outside copyright, founded on national cultural policies.

Where such schemes are part of copyright, opinions are divided as to whether the conventions oblige that country to give national treatment, or whether reciprocity can be claimed.

Some countries, like the Nordic, have already introduced legislation many years ago in order to make it easier to clear rights for mass uses -like reprography - where the effect of an agreement between the user and the rightholder's organization by law is extended also to "outsiders" on the same conditions.These schemes are clearly within copyright.

Final remarks

When international instruments, including the principle of national treatment, came into life and were revised, it was an implemental prerequisite that the parties could live with the differences inherent in national legislation. If these differences for instance regarding remuneration schemes and the level or scope of protection - differ too much, the principle of national treatment may result in an unwillingness to adhere to the revised international instruments. Worse, it may ultimately result in lack of development in the copyright field. I only point this out for the time being - as I see it as one of the problems to be resolved when trying to bridge the views of the different countries.

The socalled "information society" presents us with new challenges and possibilities - at a time when we are far from having solved the old problems and secured the access of information to all people. The copyright questions, however, are relevant -irrespective of the actual techniques of dissemination of works. The questions for the librarians remain: Are the borderlines between exclusive righ ts and the rights of the drawn user justly? Where should they be drawn when new technology is used? And I will add one more question -involving a few more -is it time for revision of the libraries' and librarians' role in the game of information dissemination? Can we foresee new forms of relationship between the librarians, the authors and the publishers and producers in the future ?

In any event: A continued and strngthened dialogue is called for between librarians, authors and producers, and with the legislators, nationally and internationally.

I look forward to the debate.

LITERATURE

BANNER, DW. The Bicentennial Celebration of the Enactment of the United States Patents and Copyright Laws. - Copyright,Nov.1990 pp 342-344

BOYTHA, G. The Justification of the Protection of Authors' Rights as Reflected in Their Historical Development. - Revue Int.de Droit d'Auteur 151 Jan.1992

DAVIES, G. The convergence of Copyright and Author's Rights- Reality or Chimera? - ICC Vol.26 Nov.1995 pp 964-972.

DREIER,T.K. - Authorship and New Technologies from the Viewpoint of Civil Law Tradition. - ICC Vol 26 No 6 1995 pp 989-999.

KNOPH, R. Åndsretten (Oslo 1936)

LASSEN, B.S. Oversikt over Norges Rett pp 837-877 (Oslo 1993)

OLSSON, A.H. COPYRIGHT. Svensk og internasjonal copyright (Stockholm 1978).

PATTERSON,L.R. and LINDBERG,SW. The Nature of Copyright.A Law of Users Right. (Athens, Georgia 1991)

PLOMAN,E.W. and HAMILTON, L.C. Copyright. Intellectual Property in the information age. (London 1980).

Regional Focus, ASIA. Intellectual Property. Oct. 1992 pp 2-12