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must file a notice,' petition the court, B95 or give the transferee another oppor tunity to exploit the work within a certain period." In addition to a reversion, or as an alternative, some statutes entitle the author to specific performance or damage, B ,B97 and many specify that the author is under no obligation to repay any remuneration he has already received.

(b) Reversion for failure to continue exploitation

Also extremely common are provisions requiring the transferee to keep works in print, to publish new editions, or to perform the work with reasonable continuity, on pain of having his exclusive rights revert to the author. Some statutes simply provide that a contract ends automatically whenever the agreed editions are out of print "irrespective of the stipulated term." B100 Others provide for the fixing of time limits for republication or performance,' or actually specify time limits within which the transferee must republish or perform in order to retain his rights." A few laws also provide criteria for determining when a work has gone out of print."

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(c) Reversion for bankruptcy or dissolution

B101

The statutes of several countries contain provisions which, under a variety of circumstances, permit reversion to the author when the transferee becomes bankrupt or ceases to exist."

B104

(3) Restrictions and presumptions concerning contractual provisions, rights and obligations

Anyone making a general survey of the current copyright laws of the world cannot fail to be impressed by the prevalence of provisions dealing with the actual content and meaning of authors' contracts. Provisions of this type now exist in the laws of at least 28 countries, and usually these provisions are both extensive and detailed. Most appear in the basic copyright statute or regulations, B106 some in the nation's organic law on contracts,* and a few in special laws or decrees. Bios Quite a number of the statutes contain general provisions dealing

B107

B See, e.g., Mexico Law of Dec. 29, 1956, arts. 46-47, 64.

B105

Ba See, e.g., Peru: Civil Code adopted by Law of May 29-June 2, 1936, art. 1680.

B See, e.g., Brazil: Civil Code promulgated by Law of Jan. 1, 1916, as amended up to Jan. 15, 1919, art. 1360; Denmark: Law of Apr. 26, 1933, § 9; France: Law of Mar. 11, 1957, art. 63; R.S.F.S.R.: Joint Resolution of Oct. 8, 1928, § 23; Uruguay: Law of Dec. 15 and 17, 1937, as amended up to Feb. 25, 1938, art. 32.

B97 See, e.g., Argentina: Law of Sept. 28, 1933, as amended up to Oct. 2, 1957, art. 46; Dominican Republic: Law of Mar. 17, 1947, art. 8; Mexico: Law of Dec. 29, 1956, art. 46; Portugal: Decree of May 27, 1927, art. 76.

B98 See, e.g., Czechoslovakia: Law of Dec. 22, 1953, §§ 48, 51, 54; Denmark: Law of Apr. 26, 1933, § 9; Dominican Republic: Law of Mar. 17, 1947, art. 8; Mexico: Law of Dec. 29, 1956, art. 46; Nicaragua: Civil Code promulgated by Decree of Feb. 1, 1904, art. 777; Poland: Law of July 10, 1952, art. 38; Sweden: Law of May 30, 1919, as amended up to Apr. 24, 1931, § 17.

BO Iceland: Law of Oct. 20, 1905, as amended up to June 5, 1947, § 9; Norway: Law of June 6, 1930, § 27; Ukrainian S.S.R.: Joint Resolution of Feb. 6, 1929, § 20; statutes cited in notes B100-02 infra.

B100 Argentina: Law of Sept. 28, 1933, as amended up to Oct. 2, 1957, art. 44; Colombia: Law of Dec. 26, 1946, art. 62; Mexico: Law of Dec. 29, 1956, art. 52.

B101 Czechoslavakia: Law of Dec. 22, 1953, § 40; France: Law of Mar. 11, 1957, art. 63; Germany: Act of June 19, 1901, as amended up to Dec. 13, 1934, § 29; Korea: Law of Jan. 28, 1957, arts. 55, 61; Peru: Civil Code adopted by Law of May 29-June 2, 1936, art. 1673; Switzerland: Code of Obligations promulgated by Federal Law of Mar. 30, 1911, art. 383; Venezuela: Law of June 28-July 13, 1928, art. 99.

B102 Denmark: Law of Apr. 26, 1933, §§ 9-10: Dominican Republic: Law of May 17, 1947, art. 8; France: Law of Mar. 11, 1957, art. 44; Iceland: Law of Oct. 20, 1905, as amended up to June 5, 1947, § 10; Italy: Act of Apr. 22, 1941, as amended up to Aug. 23, 1946, art. 124; Norway: Law of June 6, 1930, art. 28; Sweden: Law of May 30, 1919, as amended up to Apr. 24, 1931, § 18; Uruguay: Law of Dec. 15 and 17, 1937, as amended up to Feb. 25, 1938, art. 32.

B103 France: Law of Mar. 11, 1957, art. 63; Mexico: Law of Dec. 29, 1956, art. 52. B104 Austria: Act of Apr. 9, 1936, as amended up to July 8, 1953, § 32; Czechoslovakia: Law of Dec. 22, 1953, § 27; Italy: Law of Apr. 22, 1941, as amended up to Aug. 23, 1946, art. 135; Portugal: Decree of May 27, 1927, art. 64; Switzerland: Code of Obligations promulgated by Law of Mar. 30, 1911, art. 392; Venezuela: Law of June 28-July 13, 1928, art. 113.

B105 This is the case in Argentina, Austria, Brazil, Colombia, Czechoslovakia, Denmark, France, Iceland, Italy, Japan, Korea, Mexico, Nicaragua, Norway, Paraguay, Poland, Portugal, Rumania, Sweden, Turkey, U.S.S.R., and Venezuela.

B106 This is the case in Spain.

B107 This is the case in Bulgaria, Peru, and Switzerland.
B108 This is the case in Germany and Hungary.

with all types of contracts, but the most common provisions are directed specifically at transfers of publishing and performance rights; some also deal with contracts covering publication in periodicals and use in broadcasting, motion pictures, and sound recordings.

As the following summary will show, these provisions bear little or no surface resemblance to the American renewal system. To a great extent, however, their underlying purposes are identical: to protect the author against disadvantageous, unprofitable, or unfair transfers, and to put him in a position to receive an adequate and continuing return from his creation.

(a) General restrictions on contents of contracts

As might be expected, the most rigid control over an author's contract relations is found in the statutes of the Iron Curtain countries. B109 The details of these laws differ, but in general they require that every contract contain certain specified provisions. In most of these countries a government bureau provides model contracts, and no contractual provision can deviate from these models unless it is more generous to the author than they are. In certain cases the government can take over a copyright for its own purposes, but the author is still entitled to full remuneration.

Requirements that contracts specify certain definite things are by no means confined to Iron Curtain statutes. Among the most common requirements of this type are the following:

(1) The contract must state its duration, the period within which the work must be published or performed, or both;

B110

(2) The contract must specify the number of editions, copies, performances, etc., permissible under it;

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(3) The contract must specify the remuneration due the author.B

In some cases a contact is apparently considered invalid unless it contains the required provisions; for example, the Egyptian statute provides:

"In order to be valid, the act of assignment must be in writing; it must expressly specify, distinctly and in detail, each of the rights assigned, precisely defining its scope, purpose, duration and place of exploitation." B113 Usually, however, the law establishes a definite presumption-concerning the time period, the number of editions or copies, or even the amount of remuneration-which controls in the absence of a specific provision; the Italian law provides, for example:

"The number of editions and the number of copies of each edition shall be specified in the contract. However, alternatives may be provided for, either in respect of the number of editions and copies, or in respect of the remuneration based thereon.

"In the absence of such indications, it shall be understood that the contract has for its object a single edition of not more than 2,000 copies." B114

In addition, some of the statutes place a ceiling on the time periods or numbers of editions or copies which a contract can validly specify,B11 or a floor on the amount of the author's royalty.'

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Besides provisions which a contract must contain, a number of statutes specify certain provisions which are considered invalid if included in an agreement. The most common examples are provisions dealing with "personal rights" (such

B109 Bulgaria Code of Contracts and Obligations promulgated by Edict of Nov. 14, 1950, $271 Czechoslovakia: Law of Dec. 22, 1953, §§ 28, 31-32; Hungary: Decree of Apr. 21, 1951, §§ 3, 11-12; Poland: Law of July 10, 1952, arts. 33, 41; Rumania: Decree of June 18, 1956, as amended up to July 24, 1957, arts. 3, 19, 23-26; U.S.S.R.: Joint Resolution of May 16, 1928, § 17; R.S.F.S.R.: Joint Resolution of Oct. 8, 1928, §§ 18-22, 26-27, 32-34; Ukrainian S.S.R.: Joint Resolution of Feb. 6, 1926, §§ 17-19, 29; Yugoslavia: Law enacted by Decree of July 10, 1957, art. 81.

B110 See, e.g., Colombia: Law of Dec. 26, 1946, arts. 59-60; France: Law of March 11, 1957, arts. 31, 44.

B1 See, e.g., Argentina: Law of Sept. 28, 1933, as amended up to Oct. 2, 1957, art. 40; Colombia: Law of Dec. 26, 1946, art. 59: France: Law of Mar. 11, 1957, art. 51; Norway: Law of June 6, 1930, § 25; Portugal: Decree of May 27, 1927, art. 44; Sweden: Law of May 30, 1919, as amended up to Apr. 24, 1931, §17; Venezuela: Law of June 28-July 13, 1928, arts. 89-90.

B112 See, e.g., Argentina: Law of Sept. 28, 1933, as amended up to Oct. 2, 1957, art. 40; France: Law of Mar. 11, 1957, arts. 35-36, 52; Paraguay: Law of July 5-10, 1951, art. 34. B113 Law of June 24, 1954, art. 37.

B114 Act of Apr. 22, 1941, as amended up to Aug. 23, 1946, art. 122.

B115 See, e.g., Bulgaria: Code of Contracts and Obligations promulgated by Edict of Nov. 14, 1950, § 271; France: Law of Mar. 11, 1957, art. 44; Italy: Act of Apr. 22, 1941. as amended up to Aug. 23, 1946, art. 122; R.S.F.S.R.: Joint Resolution of Oct. 8, 1928, §8_19, 21-22, 33–34.

B16 See note B121 infra.

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as the various so-called "moral rights" and the "droit de suite"), which some laws make inalienable and unwaivable." Several statutes also contain provisions restricting the scope or duration of assignments of future works; and in two countries a transfer cannot validly include rights which may arise under future copyright laws, and which are greater in scope or duration than those arising under existing law. B119

B120

(b) Provisions controlling or affecting author's compensation Direct or indirect government regulation and control of the amount of remuneration an author receives appears to be a trend in recent copyright legislation. The provisions of a number of statutes establishing and regulating performing rights societies and other authors' protective associations tend in this direction, since the government is given effective control over the collection and distribution of royalties. Even more striking are the elaborate schedules of mandatory royalty rates for particular uses, which have been adopted by governments on both sides of the Iron Curtain.B Another significant development is represented by the "cultural funds"-government funds similar to the trust funds of American unions-which are created as an adjunct to the royalties paid to authors, and which are used to support indigent creators and to promote cultural projects.B12 The "lending library" funds in the Scandinavian countries, under which authors have an unwaivable right to remuneration from the secondary uses of their books, also appear to fall into this pattern.

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A number of other statutes, while stopping short of actually prescribing royalty rates, either require that the author's remuneration be stated in the contract,' or provide that a requirement of consideration will be presumed in the absence of clear language to the contrary.' An interesting and possibly portentious provision was introduced in the Italian statute in 1941 and adopted with elaborations in the new French law of 1957, it requires, as a general rule, that any total or partial transfer must be on a royalty basis, giving the author "a proportionate participation in the receipts resulting from sale or exploitation of the work.” However, a variety of exceptions, permitting lump sum assignments in particular situations, are also provided, and the practical effect of the provision is still an open question.

(c) Rules of contract interpretation

The statutes of a number of countries also contain a variety of provisions establishing presumptions and rules of contract interpretation for the author's

B117 See notes B144-50 infra, and text thereto.

B118 See, e.g., Austria: Act of Apr. 9, 1936, as amended up to July 8, 1953, § 31; France: Law of Mar. 11, 1957, arts. 33-34; Hungary: Law of Dec. 29, 1921, § 3; Italy: Act of Apr. 22, 1941, as amended up to Aug. 23, 1946, art. 120; Mexico: Law of Dec. 29, 1956, art. 42; Turkey: Law of Dec. 10, 1951, art. 48: U.A.R. (Egypt): Law of June 24, 1954, art. 40; Venezuela: Law of June 28-July 13, 1928, arts. 63-64.

Bu Italy: Act of Apr. 22, 1941, as amended up to Aug. 23, 1946, art. 119; Turkey: Law of Dec. 10, 1951, art. 51.

B120 See, e.g., Chile: Decree of Sept. 28, 1953; Czechoslovakia: Law of Dec. 22, 1953, $$ 71-72; India: Act of June 4, 1957, §§ 33-35; Italy: Act of Apr. 22, 1941, as amended up to Aug. 23, 1946, arts. 180-84; Japan: Law of Apr. 5, 1939, as amended up to June 6, 1952; Mexico: Law of Dec. 29, 1956, arts. 80-110; Switzerland: Federal Law of Sept. 25, 1940; Yugoslavia: Law enacted by Decree of July 10, 1957, arts. 69-74.

Bin See, e.g., Chile: Law of Jan. 10, 1935, Decree of May 16, 1951; Czechoslovakia: Decree of Apr. 25, 1956, as amended up to Oct. 31, 1956; Hungary: Decrees of Jan. 31 and June 14, 1958; Mexico: Rate Schedules of July 29, 1957; Rumania: Order of Oct. 5, 1950; Spain: Regulations enacted by Royal Decree of Sept. 3, 1880, as amended up to Oct. 7, 1919, arts. 96-103; R.S.F.S.R.: Joint Resolution of Oct. 8, 1928, §§ 20, 38, Resolutions of July 12, 1944 and July 15, 1947.

B122 Chile: Decree of Nov. 19, 1942; Czechoslovakia: Law of Dec. 22, 1953, §§ 73-80; Italy: Act of Apr. 22, 1941, as amended up to Aug. 23, 1946, art. 180; Norway: Law of Dec. 14, 1956.

B13 Denmark: Law of May 27, 1950; Norway: Law of Dec. 12, 1947: Sweden: Royal Decree of June 17, 1955, as amended up to Nov. 8, 1957. Proposals for funds of this type were also incorporated in the new German draft law and are being presently considered in Great Britain.

B124 See note B112 supra.

B125 See, e.g., Colombia: Law of Dec. 26, 1946, art. 58; Germany: Act of June 19, 1901, as amended up to May 22, 1910, § 22; Paraguay: Law of July 5-10, 1951, art. 34; Portugal: Decree of May 27, 1927, art. 41: Switzerland: Code of Obligations promulgated by Federal Law of Mar. 30, 1911, art. 388; Venezuela: Law of June 28-July 13, 1928, art. 102.

B128 Act of Apr. 22, 1941, as amended up to Aug. 23, 1946, art. 130.
B127 Law of Mar. 11, 1957, arts. 35-36, 52.

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benefit.B128

The general thought behind these provisions is that assignments and transfers in the copyright field should be interpreted restrictively, and that, in the absence of an express agreement to the contrary, the transfer of one right gives the transferee nothing beyond what is necessary for the exercise of that right. Although the various provisions differ widely, that of Italy can be considered fairly typical:

"In the absence of an express stipulation, alienation shall not extend to the rights of utilization in later elaborations and transformations to which the work may lend itself, including adaptations to cinematography, broadcasting, and recording upon mechanical contrivances.

"In the absence of an agreement to the contrary, the alienation of one or more of the rights of utilization shall not imply the transfer of other rights which are not necessarily dependent upon the right transferred, even if, according to the provisions of Part I, they are included in the same category of exclusive rights."

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(d) Right of author to rescind or withdraw from contract Many countries also permit the author to extricate himself from an unsatisfactory contractual relationship under certain circumstances. As we have seen, provisions entitling the author to rescind a contract if the transferee fails to exploit the work within certain contractual or statutory time limits are quite common. Other grounds for rescission are, for example: (1) “where the right to use is not exploited in accordance with the purpose for which it is granted"; " (2) "if the work is published or performed in a manner prejudicial to the value of the work"; B138 or (3) "when circumstances arise that could not have been foreseen at the time of the contract." B133 In a few countries an author is given the opportunity (sometimes for a limited time) to cancel a contract and withdraw a work for any reason, subject to indemnification of his transferee; B some statutes treat the right to wihdraw as a sort of "moral right" and restrict the author's freedom to waiye it in advance.Bi

(e) Restrictions on retransfer

One of the most common statutory provisions dealing with the author's contractual relationships involves a transferee's right to assign or license his rights to a third person. For the most part these provisions permit retransfer only with the express consent of the author or his heirs, B136 although in a few cases such retransfers are prohibited outright or require government approval. Under some provisions a retransfer may be grounds for rescission of the contract.B1

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B128 See, e.g., Austria: Act of Apr. 9, 1936, as amended up to Sept. 8, 1953, §§ 33, 36; Chile: Decree-Law of Mar. 17, 1925, as amended up to Dec. 28, 1949, art. 9; Denmark: Law of Apr. 26, 1933, § 9; France: Law of Mar. 11, 1957, arts. 30, 45; Germany: Act of June 19, 1901, as amended up to May 22, 1910, 82; Lebanon: Decree of Jan. 17, 1924, as amended up to Jan. 31, 1946, art. 146; Liechtenstein: Law of Oct. 26, 1928, art. 9 Mexico: Law of Dec. 29, 1956, arts. 24, 65-66; Norway: Law of June 6, 1930, $13: Sweden: Law of May 30, 1919, as amended up to June 24, 1955, art. 9; U.A.R. (Egypt): Law of June 24, 1954, art. 37.

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B120 Act of Apr. 22, 1941, as amended up to Aug. 23, 1946, art. 119.

B180 See notes B87-104 supra, and text thereto.

B131 Austria: Act of Apr. 9, 1936, as amended up to July 8, 1953, § 29.

B132 Czechoslovakia: Law of Dec. 22, 1953, § 44.

BIS Germany: Act of June 19, 1901, as amended up to May 22, 1910, § 35.

B14 See, e.g., Japan: Law of Mar. 4, 1899, as amended up to May 15, 1958, art. 28(8); Portugal: Decree of May 27, 1927, art. 34; Spain: Regulations enacted by Royal Decree of Sept. 3, 1880, as amended up to Oct. 7, 1919, art. 93; Venezuela: Law of June 28-July 13, 1928, art. 72.

B135 See, e.g., Austria: Act of Apr. 9, 1936, as amended up to July 8, 1953, § 29; France: Law of Mar. 11, 1957, art. 32; Italy: Act of Apr. 22, 1941, as amended up to Aug. 23, 1946, art. 142; U.A.R. (Egypt): Law of June 24, 1954, art. 42; Uruguay: Law of Dec. 15 and 17, 1937, as amended up to Feb. 25, 1938, art. 13.

B136 See, e.g., Austria: Act of Apr. 9, 1986, as amended up to July 8, 1953, §§ 27-28; Colombia: Law of Dec. 26, 1946, art. 56; Germany: Act of June 19, 1901, as amended up to May 22, 1910, § 28; Italy: Act of Apr. 22, 1941, as amended up to Aug. 23, 1946, arts. 132, 136; Japan: Law of Mar. 4, 1899, as amended up to May 15, 1958, art. 28(9): Portugal: Decree of May 27, 1927, art. 46; Turkey: Law of Dec. 10, 1951, art. 49; R.S.F.S.R.: Joint Resolution of Oct. 8, 1928, §§ 24, 44.

B137 See, e.g., Denmark: Law of Apr. 26, 1933, 10; Sweden: Law of May 30, 1919, as amended up to Apr. 24, 1931, § 18 Venezuela: Law of June 28-July 13, 1928, art. 137. B138 See, e.g., Hungary: Decree of Apr. 21, 1951, § 10; Rumania: Decree of June 18, 1956, as amended up to July 24, 1957, art. 28.

B139 See, e.g., France: Law of Mar. 11, 1957, art. 62; Rumania: Decree of June 18, 1956, as amended up to July 24, 1957, art. 28.

(f) Special obligations of transferee to author

B140

Statutory provisions establishing additional duties owed by the transferee to the author as part of their contractual relationship are also numerous. Those most frequently encountered involve: (1) the duty of the transferee to maintain accounts and to allow inspection of his books; (2) the right of the author to object to the selling price if it affects the work's dissemination; (3) the disposition of unsold copies when a contract ends; B1 and (4) the duty of the transferee to notify the author of new editions in advance and to permit him to make revisions.B143

c. Special rights reserved to the author

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In addition to rights of economic exploitation, a number of laws accord to the author certain "personal" or "moral" rights; these remain with him even when he has alienated his entire copyright, and under some statutes cannot be transferred or even waived. These "moral rights" include the right of the author to claim authorship, to divulge his work when and how he chooses, to have his name appear as author, to oppose distortions, mutilations, or other modifications that would injure his honor or reputation, and to require faithful adherence to the text of his work. The right of the author to withdraw his work from the public is sometimes considered a "moral right"; B15 the same can be said for the numerous provisions prohibiting the transferee from making any unauthorized alterations and reserving to the author the right to alter, correct, recast, or translate his work regardless of any transfers. Similarly, provisions permitting the author to publish a work in a collected edition despite an earlier transfer for separate publication (and vice versa) appear to fall into this category.

B147

It is a truism that the moral right of the author is not recognized under American copyright law, but to a limited extent the renewal system accomplishes the same result. If all contractual obligations are cut off at the end of 28 years, the author or his family regain full control not only of the right of economic exploitation, but also of all the personal rights in the work that could be called "moral." Assuming that he has not parted with his rights in the renewal term,

B140 See, e.g., Brazil: Civil Code promulgated by Law of Jan. 1, 1916, as amended up to Jan. 15, 1919, art. 1354; France: Law of Mar. 11, 1957, arts. 39, 46, 59, 60; Germany Act of June 19, 1901, as amended up to May 22, 1910, § 24; Mexico: Law of June 6, 1930, art. 67; Peru: Civil Code adopted by Law of May 29-June 2, 1936, art. 1675; Portugal: Decree of May 27, 1927, art. 52; Venezuela: Law of June 28-July 13, 1928, art. 103.

Bu See, e.g., Brazil: Civil Code promulgated by Law of Jan. 1, 1916, as amended up to Jan. 15, 1919, art. 1858; Italy: Act of Apr. 22, 1941, as amended up to Aug. 23, 1946, art. 131; Peru: Civil Code adopted by Law of May 29-June 2, 1936, art. 1678; Portugal: Decree of May 27, 1927, art. 48; Switzerland: Code of Obligations promulgated by Federal Law of Mar. 30, 1911, art. 384.

B142 See, e.g., Argentina: Law of Sept. 28, 1933, as amended up to Oct. 2, 1957, art. 43; France: Law of Mar. 11, 1957, art. 56; Germany: Act of June 19, 1901, as amended up to May 22, 1910, § 29; Italy: Act of Apr. 22, 1941, as amended up to Aug. 23, 1946, art. 133; Mexico: Law of Dec. 29, 1956, art. 51; Venezuela: Law of June 28-July 13, 1928, art. 105.

B143 See, e.g., Japan: Law of Mar. 4, 1899, as amended up to May 15, 1958, art. 28(7); Korea Law approved by Proclamation of Jan. 28, 1957, art. 52; Mexico: Law of Dec. 29, 1956, art. 44; Poland: Law of July 10, 1952, art. 39; Portugal: Decree of May 27, 1927, art. 57; Switzerland: Code of Obligations promulgated by Federal Law of Mar. 30, 1911, art. 385.

B144 For a general discussion of the author's moral right, see Strauss, The Moral Right of the Author. [Study No. 4 in the present series of committee prints.]

B145 See notes B-130-35 supra, and text thereto.

B146 See, e.g., Argentina: Law of Sept. 28, 1933, as amended up to Oct. 2, 1957, arts. 3839, 51 Brazil: Civil Code promulgated by Law of Jan. 1, 1916, as amended up to Jan. 15, 1919, arts. 659, 1350; Finland: Law of June 3, 1927, as amended up to Mar. 28, 1941. § 22; France: Law of Mar. 11, 1957, art. 56; Germany: Act of June 19, 1901, as amended up to May 22, 1910, §§ 12-13, 20; Hungary: Law of Dec. 29, 1921, § 3; Iceland: Law of Oct. 20, 1905, as amended up to June 5, 1947, § 9; Korea: Law approved by Proclamation of Jan. 28, 1957, arts. 16, 17, 42; Mexico: Law of Dec. 29, 1956, arts. 24, 40-41: Netherlands: Law of Sept. 23, 1912, art. 25; Nicaragua: Civil Code promulgated by Decree of Feb. 1, 1904, arts. 742, 768: Paraguay: Law of July 5-10, 1951, art. 33; Poland: Law of July 10, 1952, arts. 31, 42; Portugal: Decree of May 27, 1927, arts. 56, 62, 75; Spain: Regulations enacted by Royal Decree of Sept. 3, 1880, as amended up to Oct. 7, 1919, art. 66; Switzerland: Code of Obligations promulgated by Federal Law of Mar. 30, 1911, arts. 385, 387; Turkey: Law of Dec. 10, 1951, art. 55; Venezuela: Law of June 28-July 13, 1928, arts. 67-68, 93-94, 125.

B147 See e.g., Austria: Act of Apr. 9, 1936, as amended up to July 8, 1953, § 34; Czechoslovakia: Law of Dec. 22, 1953, § 38; France: Law of Mar. 11, 1957, art. 36; Japan: Law of Mar. 4, 1899, as amended up to May 15, 1958, art. 28(3); Norway: Law of June 6, 1930, § 27; Poland: Law of July 10, 1952, art. 45; Venezuela: Law of June 28-July 13, 1928, arts. 66, 86, 88.

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