Comparative Analysis of Copyright Regimes in Nigeria, the United States of America and France

Abstract

This paper deals with a comparative analysis of the copyright regimes Nigeria, the United States of America (U.S.) and France with a view to identifying impart areas from which to derive lessons. The United States is chosen because it is one of the most developed economies where the copyright industry has thoroughly developed to add to the country’s GDP. It has its copyrights roots in the common law, same as Nigeria. France is chosen because, it is a country which is also advanced in copyright development-the place of birth of the first international copyright treaty, the Berne Convention. This is added to the fact that France is a Civil law country and will offer interesting areas of comparison to the common law system.