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Canadian Copyright Law
Copyright law in Canada largely reflects international treaties signed by it. Canada is
a party to the Berne Convention for the
Protection of Literary and Artistic Works of 1886.
The Canadian case, CCH Canadian Ltd. v. Law Society of Upper Canada, re-evaluated the
meaning of "original" and found
that for a work to be original it must be the result of the exercise of "skill and
judgement".
Skill, means the "use of one's knowledge, developed aptitiude or practised ability in
producing work", and judgement, meaning
the "use of one's capacity for discernment or ability to form an opinion or
evaluation by comparing different possible options in
producing the work".
Originality does not require any novelty or creativity though it requires intellectual
effort beyond mere mechanical exercise.
The determination of originality on the basis presented in CCH Canadian depends on the
facts. For a large part, it depends on
degree to which the work originated from the author. The medium or form used is
significant. Whether it comprises elements
that are in the public domain or not, whether it the ordering of data or facts, or whether
the form is pedestrial or novel. Mere
selection is generally not enough. As well, it is significant to consider whether there
are any artistic elements to it.
Copyright provides the protection of expression of ideas. This entails that there must be
a form, or "fixation", to the expression.
It is fixation that distinguishes an expression from an idea.
In Canadian Admiral Corp. v. Rediffusion, the court considered fixation: "for
copyright to exist in a 'work' it must be expressed
to some extent at least in some material form, capable of identification and having a more
or less permanent endurance". In this
case, the court found that there was insufficient fixation in the live broadcast of a
sports event. Any sort of broadcast, telecast,
or display of a spectacle on its own is not sufficient to be fixed. At the least, it must
be simultaneously recorded in some fashion
to be fixed.
To the possible exception of choreographed works, there is a requirement that the work be
recorded in a relatively permanent
form. Typing a note into a computer screen may be sufficiently permanent. Some cases have
shown that unstructured speech
or other spontaneous or improvised creations, such as a sports game, cannot contain
copyright.
Both facts and ideas are by their very nature uncopyrightable. This will often create
difficulties when it becomes necessary to
separate the idea from the expression as well as in the separation of fact from the
arranging and use of those facts. Where the
distinction between idea and expression becomes obscured the Courts often take a
precautionary view that it cannot be
copyrighted so as to let others express the same idea.
Minor designs that are largely ornamental or functional like coloured blocks used as tools
in an educational program are
excluded..
The copyright of an artist's work is owned directly by the artist with the exception of
works created in the course of
employment.
Government works
Section 12 of the Copyright Act reserves copyright for all works produced by the
government for a period of 50 years
following the end of the calendar year when the work has been performed, unlike the United
States, where the government
does not hold copyright. In addition, the Copyright Act applies to government works, but
"without prejudice to any rights or
privileges of the Crown".
All documents produced by the Government of Canada belongs to the Government.
Section 12 of the Copyright Act is the provision dealing with Crown copyright and gives
copyright to the Crown in works that
are prepared or published by or under the direction or control of Her Majesty or any
government department.:
"Without prejudice to any rights or privileges of the Crown, where any work is, or
has been, prepared or published by or
under the direction or control of Her Majesty or any government department, the copyright
in the work shall ... belong to Her
Majesty and ... shall continue for the remainder of the calendar year of the first
publication of the work and for a period of fifty
years following the end of that calendar year"
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