Refers to the Berne Convention [Treaty] for the Protection of Literary and Artistic Works of September 9, 1886, which has been repeatedly revised, most recently in 1979. It is the primary international agreement protecting copyright around the world and sets a common basis for protection and also provides that a work of authorship in any subscribing state immediately creates “copyright” in all other subscribing states. Most major economies are now members of the Berne Convention. Significant subsidiary agreements to “Berne” are found in the WIPO Copyright Treaty. Most amendments have extended the rights of copyright holders, limiting existing property rights is unheard of and likely unconstitutional in many members of the convention.