Generally speaking, copyright theory and practice can be characterized as divided into two broad copyright cultures. On the one hand, in common law jurisdictions, copyright is regarded as a policy instrument designed to serve the public interest in the production and dissemination of works of authorship. Not the author’s right, but the public interest that both generates and justifies that right is the central animating concern of copyright law. On the other hand, in civil law jurisdictions, authorial entitlement is conceived not instrumentally but as a juridical recognition of rights inherent in the act of authorship as such. Not the public interest, but the inherent dignity of authorship is the axis around which copyright revolves. Terminologically speaking, these distinctions recall for us that what the common law world regards as copyright is rather known as author’s right (droit d’auteur, derecho de autor, diritto de autore, urheberrecht, for example) in the civil law world.