A Comparison Among UK, Germany And Netherlands On Public Lending Right And Its Enlightenment For China

With the gradual strengthening of the international intellectual property trends and therapid development of national library career, Public Lending Right gradually emerges whereattaching our attention. The so-called Public Lending Right is copyright owners or the personof neighboring right’s copyrighted works or copyright products are free to public libraries forborrowing and getting some compensation for remuneration rights. The year of1992EU lawimplement political and economic integration, particularly the European Union EC92/100Directive issued, Public Lending Right in some countries established rapidly. Affected by theWorld Intellectual Property Center-European Union, other countries have also begun toexplore the possibility of establishing a Public Lending Right Scheme. The history of PublicLending Right is not long, only half a century, and second established PLR schemes after theScandinavian countries, as the earlier implementation of the Public Lending Right countries,the Netherlands, Germany, the United Kingdom also basically represents the entire history ofthe public lending right, but as a quasi-public lending right on behalf of the most successfulcopyright model-the United Kingdom, on behalf of the writings of exclusive rights-Germany, as well as the implementation of the most thorough instruction EC92/100Netherlands, three public lending Right countries are unique and more reference to China,worth further exploration of research. As an earlier implementation of the Public LendingRight after Scandinavian country, the Netherlands, Germany, and the UK Public LendingRight were unique. In this paper, the development process of the Public Lending Right inthree countries, legislative model, regulatory agencies, the main object of the right content,the source of the compensation calculation and allocation rules in some way to explore,compare their similarities and differences, in order to build our own country’s PLR schemeexperience in the future.