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374

COPYRIGHT

Variations in

copyright

terms

The new British code

because qf first publication in England, but the stat- ute of 1842 was construed to alter this. In the ruling case under the last-named statute, Routledge v. Low, in 1868, Lords Cairns and Westbury laid down ex- plicitly that first publication was the single necessity, and that copyright was not strengthened by resi- dence; though Lord Cranworth objected and Lord Chelmsford doubted whether this was good law. It was because of this doubt that American authors had been accustomed to make a day's stay in Mon- treal on the date of English publication of their books. This decision was accepted by the law officers of the Crown and became in 1891 the basis for the reciprocal relations proclaimed by the President of the United States.

The copyright term in Great Britain has differed for the several subjects of copyright, under the divers acts as stated in previous chapters, the general term being for life and seven years or for forty-two years, whichever the longer. Registration at Stationers' Hall has been requisite only (except in the case of works of art) as preliminary to suit, and infringe- ment previous to registration was punishable. De- posit of one copy in the British Museum has been re- quired within a stated time from publication, but only on penalty of fine and not forfeiture of copyright, and the four university libraries might demand copies. Under the international copyright acts, registration and deposit at Stationers' Hall for transmission to the British Museum was requisite for foreign works; but this was made unnecessary by the adhesion of Great Britain to the International Copyright Union.

The Copyright Act, 191 1, as amended by the Lords, which became law (i & 2 Geo. v. c. 46) on Crown approval December 16, 191 1, provides a codi- fication for the British Empire as comprehensive as