When the protection of moral rights is brought up in the United States, commentators have always emphasized the differences between continental Europe and the United States.2 Cases that have been widely used as textbook illustrations include Soc. Le Chant de Monde v. Soc. Fox Europe3 and Turner Entertainment Co. v. Huston.4 While the Anglo-American copyright regime and the French authors right (droit dauteur) regime were quite similar in the eighteenth century, 5 the protection of moral rights did not attain formal international recognition until 1928.6 The gap between the U.S. and French systems has also grown considerably since the enactment of the 1909 U.S. Copyright Act.
