A Comparative Study of the Right of Attribution in the Legal Systems of Iran, the United Kingdom, and the United States of America

The attribution right of the authors of literary and artistic works, as one of the types of moral rights, consists of positive and negative aspects. Because of these aspects, the author should be introduced as the creator of the work and the false attribution of the work to a third person should be prevented. Given the protection of this right in the law of Iran, the United Kingdom and the United States of America, the present study attempts to examine the concept, aspects and scope of the right of attribution in these legal systems in a descriptive-analytical and comparative method. The results of this study indicate that although there are differences arising from the different legal structures and ideas of these legal systems, the creators of literary, artistic, dramatic and musical works can protect their name and identity. Of course, the duration of this right is not the same and contrary to Iranian law, in the United Kingdom and the United States of America, the protection of the author’s name is temporary.