The Imperial Copyright Act of 1911, s. 31, provided that: “No person shall be entitled to copyright … otherwise than under and in accordance with the provisions of this Act” or other enabling statute. Thus copyright became a purely statutory right; however, the English courts continued to refuse copyright protection for obscene works, apparently without consideration of this change. An example is Glyn v. Weston Feature Film Co., [1916] 1 Ch. 261, in which the plaintiff brought an action for the alleged infringement by the sale and exhibition of a burlesque film.
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