Primary Law:
Copyright Act, 1957 (as last amended by Act No. 49 of 1999)
Secondary Sources:
Introduction to Indian Copyright (general background information)
Sections
Article 2 (definitions section) defines "authors".
Chapter IV of the Act deals with ownership rights.
Terminology
"Contract of Service" means employment contract.
"Contract for Service" is similar to the American independent contractor relationship.
In India, "moral rights" are called "author's special rights" and can be found under that phrase.
European Commission Directive on Software: Directive 2009/24/EC
Directive 2009/24/EC replaces an earlier 1991 directive that had been the first copyright measure adopted in the European Economic Union aimed toward the creation of a single market. The objective of the Directive is to harmonize Member States' legislation regarding the protection of computer programmes in order to create a legal environment which will afford a degree of security against unauthorized reproduction of such programmes.
Primary Law:
French Code of Intellectual Property (English Translation, last updated 2003)
Explaination of Terms/Sections:
"Work for Hire" is often called "Contract for hire" or "Contract of service".
IP Code Art. 111-1 provides the basic author rights.
IP Code Art. 111-1 provides the basic employment provision for french copyright authorship.
IP Code Art. 113-9 provides the special copyright rules relating to software.
IP Code Art. 121 covers the author's moral rights; Art. 122 covers "exploitation" (economic) rights.
IP Code Art. 131-1 through 131-3 provides the basic rules concerning assignment clauses in an employment context.
Secondary Sources
Primary Law:
German Copyright Act. The translation includes the amendment(s) to the Act by Article 8 of the Act of 1.10.2013 (Federal Law Gazette I p. 3714). Full text.
Explanation of Terms/Sections:
Germany does not use the term "works for hire". It generally will use the term "Employment" or "service" to refer to issues of ownership of copyright vis a vis employment. Germany also does not refer to "software" but rather "computer programs".
The term "mutatis mutandis," used occasionally in the German law, means "apply the same principle to another situation, but with any minor differences necessary to apply it."
Article 7 provides information about authorships.
Article 10 provides the presumption of copyright authorship.
Article 29 governs copyright transfer.
Article 31 governs exploitation rights (i.e. licenses or permissions to exploit).
Articles 32-35, 37, and 39-42 deal with author's rights when he/she grants exploitation rights.
Article 43 provides the general rule concerning authorship in the context of employment.
Section VIII (Article 69a-69g) provides the special provisions as it relates to computer programs.