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In cases of overseas internet disputes (e.g. defamation/copyright), what test would one use for jurisdiction?
I'm aware of the tests for cross-border in the EU, or cross-state jurisdiction in the US, but have found very little information when the two jurisdictions cross each other.
If the copyright infringement was of a Spanish book for example by a US website, what would be the appropriate test to use, the EU or the USA copyright jurisdiction test? Would one use the test in the jurisdiction/he should would like to make a claim?
Just something that is confusing me so would be great if anyone had any analysis.
I'm aware of the tests for cross-border in the EU, or cross-state jurisdiction in the US, but have found very little information when the two jurisdictions cross each other.
If the copyright infringement was of a Spanish book for example by a US website, what would be the appropriate test to use, the EU or the USA copyright jurisdiction test? Would one use the test in the jurisdiction/he should would like to make a claim?
Just something that is confusing me so would be great if anyone had any analysis.
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