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Moral rights were first recognized in France and Germany, before they were included in the Berne Convention for the Protection of Literary and Artistic Works in 1928.
Canada recognizes moral rights ( droits moraux ) in its Copyright Act ( Loi sur le droit d ' auteur ).
While the United States became a signatory to the convention in 1989, it still does not completely recognize moral rights as part of copyright law, but rather as part of other bodies of law, such as defamation or unfair competition.

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