the combined forces of the Holy Alliance; for it was no secret that the Monroe doctrine, for many years after it was first put forward, really meant that a European aggressor would find his way to the shores of the American continent barred by the British fleet. Everywhere in South America the Englishman is trusted and is welcomed; and, if in the future he finds himself ousted from the predominant position he has hitherto held in South American trade, it will be through his own fault.

The nearness of the United States of America ensures to the great republic of the north a large share of the trade with Mexico, and to a less degree with the other countries of Latin America. Nevertheless, it is a remarkable fact that very few citizens of the United States are to be found south of the isthmus of Panama. The South American republics have from time to time shown a readiness to shelter themselves, in their difficulties with European creditors, behind the Monroe doctrine; and eloquent orations filled with expressions of brotherhood and friendliness have marked the opening and the close of Pan-American Congresses. But at bottom there is no love lost between the Latin republics and the United States. The ideals of the North and South are not merely dissimilar, but antagonistic. The hegemony implied by the Monroe doctrine, even if not openly asserted, is, as we have already pointed out, resented in South America. Many things are possible in that vast and varied quarter of the world; and the present century will undoubtedly witness there a process of growth and evolution the precise form of which cannot be at present with clearness foreseen; but it may be predicted with certainty that Latin America will never without an obstinate struggle consent to become in any sense a political appendage of the United States.

Art. 8.-COPYRIGHT LAW REFORM.

1. A Bill to Amend and Consolidate the Law relating to Copyright. London: Wyman, 1910.

2. Memorandum of the Proceedings at the Imperial Copyright Conference, 1910. London: Wyman, 1910.

3. Report of the Committee on the Law of Copyright. London: Wyman, 1909; and Minutes of Evidence, with Appendix. London: Wyman, 1910.

4. Correspondence respecting the Revised Convention of Berne for the Protection of Literary and Artistic Works. London: Wyman, 1909.

THE introduction by the President of the Board of Trade of a Bill to amend and codify the law relating to copyright is the latest of a series of important events to which the general public has given little heed. The Berne Copyright Convention (1887), to which almost all the leading countries of the world, except the United States, are parties, was revised at an International Conference held at Berlin, under the auspices of the German Government, in October and November 1908. The revised Convention was exhaustively examined in 1909 from the point of view of the United Kingdom by a strong Departmental Committee, of which Lord Gorell was Chairman. Finally, the methods of securing the co-operation of the whole Empire, in a renewed effort to reform the Copyright Law, were discussed, with the revised Convention as a text, at a conference with representatives of the self-governing Dominions and India, under the presidency of Mr Sydney Buxton, in May and June of the present year. These preliminary investigations have made incontestable the urgent necessity of reforming the British Copyright Law for at least three separate reasons: first, on account of its inherent defects; secondly, in order to place the copyright legislation of the Empire on a stable foundation; and thirdly, for the sake of enabling the revised Convention to be ratified, in accordance with the emphatic recommendation both of

* The members of the Convention are now: Belgium, the British Empire, Denmark, France, Germany, Hayti, Italy, Japan, Liberia, Luxemburg, Monaco, Norway, Spain, Sweden, Switzerland and Tunis. There is reason to hope that Holland will soon join the Convention.

the Copyright Committee and of the Imperial Copyright Conference.

Copyright law reform has received a great deal of attention on the continent of Europe during the last thirty years, and has been pressed in various ways upon the notice of the practical legislator. France has led the way. Curiously enough, her own copyright law consists mainly of a vague and almost crude enactment dating from 1793; but the generous interpretation which it has received has placed France in the forefront of the nations in most questions affecting authors' rights. Other nations, lacking perhaps the French genius for generalisation, have worked out elaborate codes of copyright law, revising them from time to time, but always to the author's advantage, under the impulse of modern thought. The result is that, with the exception of Great Britain, all the countries of Europe which make any pretence to advanced civilisation have conferred upon authors the inestimable boon of a copyright law imbued with modern tendencies. Nor has this advance been confined to Europe. Japan has progressed very rapidly in the same direction; the Spanish States of South America have followed the example of their mother-country; and in the early part of last year the United States adopted a new code which, though open to serious objection in some of its details, is yet in the main an enlightened and liberal measure.

The Berne Copyright Convention of 1887 was the first important manifestation of the growing tendency towards the fuller recognition of the author's rights, not only in his own country, but in all countries. At the time it was a novel and daring venture. There were numerous copyright treaties in existence, but there was nothing on so ambitious a scale as the Convention, embracing, as it did, nine different countries. Its fundamental principle was that each signatory should treat the subjects of other members of the Union in the same way as it treated its own subjects. To give this principle coherence and to secure a proper measure of reciprocity, there was also laid down, in certain important matters, a definite minimum of protection which every member of the Union should be bound to grant.

The provisions of the Convention could not be other than a compromise. The necessity for unanimity made

it inevitable that many important elements of an author's rights should be left obscure, or even definitely restricted; at the best they were placed within the discretion of the contracting parties. The framers of the Convention, however, held fast to the principle that what was guaranteed was only a minimum of protection; there was to be no obstacle to the grant of more extensive rights. This principle found definite expression in the provision that periodical conferences should be held for the revision of the Convention.

The first of these conferences was held in Paris in 1896. The time was not ripe for sweeping alterations in the Convention; England, in particular, was unable to agree to any changes but such as were of comparatively little moment. Certain amendments, however, some of considerable importance, were found to be practicable, and, in the absence of complete unanimity, instead of being incorporated in the Convention itself, were embodied in an additional Act and an Interpretative Declaration, the latter of which was not accepted by the United Kingdom.

The ten years which succeeded 1896 witnessed a great advance. The old Convention, which in its origin marked the utmost limits of concession and was indeed almost in advance of public opinion, was definitely overtopped by the wave of progress which it had itself been very largely instrumental in raising. Its provisions were generally felt to be unduly restrictive of the author's rights. France, Germany, Italy and Belgium entered into a series of copyright treaties with one another, granting reciprocal privileges more in accordance with the enlightened legislation of those countries. A revision of the old Convention became inevitable, and was carried out by the Conference of Berlin in 1908, not without considerable concessions to weaker brethren, but on the whole with remarkable liberality. The labours of the Conference resulted in the preparation of a single amended text; this was signed on behalf of all the members of the Union, and, when ratified, takes the place of the three documents by which these countries are now bound.

Great Britain had been to all appearance unaffected by the movements which led to this revision. In 1896 she had pursued a policy of obstruction, owing to the

defective state of her copyright law; and, as this law had not been altered for the better, it was naturally feared that she would adhere to the same policy in 1908-a course which might render fruitless the labours of the Conference or might even lead to the disruption of the Union. But the indefinable force of opinion had not been without its effect. The British delegates at Berlin were authorised to make substantial concessions, and affixed their signatures to the revised text. Their action is endorsed by the Copyright Committee.

'In conclusion' (says the Report), 'we desire to express our approval of the Revised Convention as a whole. In our opinion, though containing certain defects and ambiguities imposed by the necessities of International agreement, it marks a very great advance on the original Berne Convention and the Acts of Paris; and we trust it will not be out of place for us, after an exhaustive study of the text, to endorse the action of the British delegates, the late Sir Henry Bergne, K.C.B., K.C.M.G., Mr G. R. Askwith, K.C., C.B., and Count de Salis, C.M.G., in signing the Revised Convention on behalf of this country.'

The decision of the Imperial Copyright Conference is equally emphatic.

"The Conference' (says the first of its resolutions) 'having considered in substance the revised Copyright Convention, recommends that the Convention should be ratified by the Imperial Government on behalf of the various parts of the Empire; and that, with a view to uniformity of International Copyright, any reservations made should be confined to as few points as possible.'

To indicate the bearing of these recommendations on the Copyright Bill, it is sufficient to point out that there is hardly one of the changes made in the revised Convention, certainly no important one, that can be brought into effect in this country without an amendment of the Copyright Law.

The problem of Imperial Copyright is familiar to all who have followed the history of this question; it is probably not too much to say that, were it not for the difficulty arising from the constitution of the Empire, the Copyright Law would have been remodelled long ago. The problem lies on the surface. No fundamental amend