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Comment by henvic | Hacker News Reader

"The Digital Millennium Copyright Act (DMCA) is a 1998 United States copyright law."

Last time I checked the Netherlands was a different country. lol

By the way: https://www.websiteplanet.com/blog/dmca-ignored-countries/

DMCA is just a letter format for removal of content per U.S. law. Any country that observes copyright (they are apart of the WTO) is expected to comply with other member nations' copyrights. All developed countries have also adopted the Berne Convention.

That is a pretty big simplification, both partly true and false. There is international cooperation but copyright has significant differences between countries and having a copyright claim in one country does not always mean you have it in another.

And which of these treaties exactly has a problem with the reverse engineering work done here? Nobody is claiming that Tesla doesn't have copyright on their software, if that copyright allows them to restrict this work is an entirely different kettle of fish, and depending on local laws.

You're right, I don't think there was ever a DMCA claim actually made, and probably would not be valid. Just replying to the misleading statement as if copyright from other countries have no standing.

They didn't claim that copyright from other countries has no standing, but correctly pointed out that claims under other countries copyright laws are irrelevant.

It’s actually exactly the other way around: countries don’t comply with other countries’ copyrights, but they must offer the same level of protection to authors of works created abroad as they give to authors of works created locally (I.e. non-discrimination of foreign works/authors). And they must also offer a minimum level of copyright protection as specified in the convention. The egregious content removal remedies offered by the DMCA in the US are luckily not part of those minimum protections, so most sane countries have a more balanced procedure for content removal remedies.

If you think that the US is (relatively) insane when it comes to this, you have never witnessed the German equivalent (which is much more complainant-friendly).

DMCA also makes lot's of reverse engineering illegal. And that is the relevant issue here.

The whole point of DMCA is that it's a relatively recent extensions/addition to the copyright law that USA had before, which matched the Berne convention.

The non-DMCA parts of copyright are pretty much the same in USA as across the whole world, as they have been harmonized with international treaties. The extra requirements of DMCA (e.g. restrictions on circumventing technical measures of copyright protection), however, are country-specific and not widespread elsewhere.

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