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The United States ‘fair use’ exception is one that other jurisdictions,…
The United States ‘fair use’ exception is one that other jurisdictions, such as the UK, should adopt.
Comparison of fair use vs fair dealing vs other exception regimes
Fair use history (development from common law)
Fair use and fair dealing
Other exception regimes (developing nations)
The four factors
Purpose and character of the use (including whether commercial or educational)
Nature of the work
Amount and substantiality of portion used in relation to work as a whole
Effect on the potential market or value of the work
Market failure test
Functional test
Impact on derivative works
Whether original work published
Legal system flexibility and technological change
Google books
Philosophy of copyright law
Freedom of speech
Utilitarian
Natural law / author centred
Case law
Fair use
Folsom v March
Fair dealing