An accurate and in-depth analysis of the American protection of authors’ moral rights has been presented in the publication in April 2019 of a study by the Copyright Office. This study has been published thirty years after the United States’ adhesion to the Berne Convention. This paper examines the document in relation to the situation of the non-economic author’s rights in Europe, in the light of their historical origins, of the Directives and in particular of that Copyright definitively approved a few days before the Copyright Office document. While in the USA the limited interest in moral rights seems to be increasing, in Europe the protection of moral rights risks waning being left to individual countries and the declaration that it is not the object of the Directives has been made explicit.
KEYWORDS: USA, moral rights, European directives
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Sommario: 1. Il Berne Convention Implementation Act: un anniversario importante. 2. Le direttive europee e i diritti morali: un’occasione mancata. 3. Per un diritto transcontinentale?