Ricerc@Sapienza

An accurate and in-depth analysis of the American protection of authors’ moral rights has been presented in the publication in April 2019 of a study by the Copyright Office. This study has been published thirty years after the United States’ adhesion to the Berne Convention. This paper examines the document in relation to the situation of the non-economic author’s rights in Europe, in the light of their historical origins, of the Directives and in particular of that Copyright definitively approved a few days before the Copyright Office document.

The USA joined the 1886 Berne Convention for the Protection of Literary and Artistic Works only in 1989, with the Berne Convention Implementation Act (BCIA). Thirty years later, the Copyright Office published in April 2019 an extensive study about the American protection of moral rights. The document is studied in comparison with the European Directives and in particular with the Copyright Directive definitively approved a few days before the Copyright Office document.