Rapport The Treatment of Parodies under Copyright Law in Seven Jurisdictions: A Comparative Review of the Underlying Principles, Parody and Pastiche. Study II. January 2013, UK Intellectual Property Office.
"The purpose of this paper is to review the legal treatment of parodies in several key countries, with a view to identifying possible regulatory options for benefiting from a parody exception to copyright infringement, and distilling the (economic and non-economic) rationales underlying tests developed by legislators and courts. The selected jurisdictions share a common law heritage with the UK (Australia and Canada), or have contributed significantly to the European acquis (Germany, France and The Netherlands). The selection also includes countries with an explicit parody exception (Australia, France and The Netherlands), and countries that accommodate parody within a wider “fair use” provision (USA) or a narrow “free use” provision interpreted in the light of constitutional norms of freedom of expression and freedom of the arts (Germany).
It will be seen that the criteria developed for assessing parodic treatments in these jurisdictions overlap in complex ways (often fusing economic, moral, and social elements). The order of countries broadly follows a progressive liberalisation, from more restrictive to less restrictive regimes."
Lees het rapport hier.