A Comparative Analysis of The Liability of Internet Service Providers in The Context of Copyright Ingfingement in The U.S., European Union And Poland

Malgorzata Lesiak

Abstract

The subject matter of the present article is the legal position of Internet Service Providers which has been hotly debated in the US and then in the EU for more than a decade now. Although the European model has been inspired to a significant degree by the American solution, several important differences are present. This is not only a result of a copyright-centered American paradigm, which can be contrasted with a horizontal regulation of the liability of intermediaries in the European directive on electronic commerce. The aim of this contribution is to discuss the most important differences between the two regimes, with a special emphasis on the position of online intermediaries in Poland.

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