copy.^3389 Moreover, differing standards could apply – the same intermediate copy created in the
course of transmission through the Internet could be considered infringing when passing through
one country, and not when passing through another. In addition, the violation of the rights of
transmission and access under the WIPO treaties might occur in yet another country. Although
the WIPO treaties may afford a vehicle for greater transnational uniformity of copyright law,
there is no guarantee that implementing legislation in the various signatory countries will be
consistently adopted, consistently interpreted, or consistently applied.
In sum, copyright owners may have potentially unprecedented rights over use of their
copyrighted material on the Internet. One can expect that the fair use and implied license
doctrines (and their international equivalents) will take center stage in resolving the balance
between copyright owners’ and users’ rights on the Internet. How broadly these doctrines will
be applied, and whether they will be consistently applied in various countries, remains to be
seen. Copyright lawyers will continue to be busy.
(^3389) In addition, at least one court held that where predicate acts occurred in the U.S. leading to infringements that
occurred abroad, damages flowing worldwide from a U.S. infringement could be considered. Update Art, Inc.
v. Modiin Publishing, Ltd., 843 F.2d 67 (2d Cir. 1988).