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Statute of Anne
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===Significance=== The Statute of Anne is traditionally seen as "a historic moment in the development of copyright", and the first statute in the world to provide for copyright.{{sfn|Deazley|2006|p=13}} Craig Joyce and [[Lyman Ray Patterson]], writing in the ''Emory Law Journal'', call this a "too simple understanding [that] ignores the statute's source", arguing that it is at best a derivative of the Licensing Act. Even considering this, however, the Statute of Anne was "the watershed event in Anglo-American copyright history ... transforming what had been the publishers' private law copyright into a public law grant".{{sfn|Patterson & Joyce|2003|p=916}} Patterson, writing separately, does note the differences between the Licensing Act and the Statute of Anne; the question of censorship was, by 1710, out of the question, and in that regard the statute is distinct, not providing for censorship.{{sfn|Patterson|1965|p=236}} It also marked the first time that copyright had been vested primarily in the author, rather than the publisher, and also the first time that the injurious treatment of authors by publishers was recognised; regardless of what authors signed away, the second 14-year term of copyright would automatically return to them.{{sfn|Bracha|2010|p=1438}} Even in the 21st century, the Statute of Anne is "frequently invoked by modern judges and academics as embodying the utilitarian underpinnings of copyright law".{{sfn|Alexander|2010|p=17}} In ''[[IceTV v Nine Network]]'',<ref>[2009] HCA 14</ref> for example, the [[High Court of Australia]] noted that the title of the statute "echoed explicitly the emphasis on the practical or utilitarian importance that certain seventeenth-century philosophers attached to knowledge and its encouragement in the scheme of human progress".{{sfn|Alexander|2010|p=17}} Despite "widely recognised flaws", the Act became a model copyright statute, both within the United Kingdom and internationally.{{sfn|Bently|2010|p=11}} [[Christophe Geiger]] notes that it is "a difficult, almost impossible task" to analyse the relationship between the Statute of Anne and early French copyright law, both because it is difficult to make a direct connection, and because the ongoing debate over both has led to radically different interpretations of each nation's law.{{sfn|Geiger|2010|pp=122β123}} Similarly, Belgium took no direct influence from the statute or English copyright theory, but Joris Deene of the [[University of Ghent]] identifies an indirect influence "at two levels"; the criteria for what constitutes copyrightable material, which comes from the work of English theorists such as Locke and [[Edward Young]],{{sfn|Deene|2010|p=141}} and the underlying justification of copyright law. In Belgium, this justification is both that copyright serves the public interest, and that copyright is a "private right" that serves the interests of individual authors. Both theories were taken into account in ''Donaldson v Beckett'', as well as in the drafting of the Statute of Anne, and Deene infers that they subsequently affected the Belgian debates over their first copyright statute.{{sfn|Deene|2010|pp=142β143}} In the United States, the [[Copyright Clause]] of the [[United States Constitution]] and the first Federal copyright statute, the [[Copyright Act of 1790]], both draw on the Statute of Anne. The 1790 Act contains provisions for a 14-year term of copyright and sections that provide for authors who published their works before 1790, both of which mirror the protection offered by the statute 80 years previously.{{sfn|Patterson & Joyce|2003|p=939}}
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