A few countries still grant copyright in perpetuity, but usually the
term of protection is limited either to a certain number of years, or to
a term of years beyond the date of the author's death. This last
provision is the more general, and the term varies from seven years
after the author's death in England, for instance, to eighty years after
the author's death in Spain. The two most common terms are thirty years
to fifty years beyond the life of the author. Our own legislation
provides for two possible terms of protection. The first being for
twenty-eight years from the date of the recording of the title in the
Copyright Office, and the second, an extension of fourteen years from
the expiration of the first term.
Besides the time limit, copyright--especially as far as the authors of
the United States are concerned--is limited territorially, not extending
beyond the boundaries of the United States. Whether the protection which
follows registration and deposit shall extend so as to include Porto
Rico, Hawaii and the Philippines is a matter of some question. Probably
as regards the Philippines the answer would be in the negative, but as
concerns Porto Rico, since the passage of the "Act temporarily to
provide revenue and a civil government for Porto Rico" (April 12, 1900)
and Hawaii, since the taking effect (June 14, 1900) of the "Act to
provide a government for the territory of Hawaii," the response would be
in the affirmative.
The obtaining of copyright protection by a compliance with the United
States statutory requirements as to registration of title, deposit of
copies, and printing of notice of copyright, does not secure extension
of this protection in the territory of any foreign country, the United
States not being a member of the International Copyright Union. An
American author must comply with the requirements of the copyright laws
of a foreign country, just as if he were a citizen or subject of that
country, in order to obtain copyright protection within its borders.
Presumably, however, the obtaining of valid copyright protection in one
of the countries of the International Copyright Union, England for
example, would secure protection throughout the various countries of
that Union.