As excep？？es aos direitos de autor em benefício das bibliotecas: análise comparativa entre a Uni？o Europeia e a América Latina

the development of the digital environment it became essential a general reformation of copyright legislation, including the exceptions that benefit libraries and similar institutions. this adaptation to the new technological reality is not to process of a satisfactory form in the majority of the countries, not only for the extreme reinforcement of the copyrights, as for the maintenance of a certain pre-digital philosophy. this legislative reform would have to be become fulfilled having in account the interests and the level of development of each country, therefore the objectives diverge between the countries of the north america and the europe, in relation to the countries of latin america. the objective of this work consists of analyzing the situation where if they find the library exceptions in the main countries of the european union and latin america, examining its differences and similarities. it is concluded that, although the national laws of the european countries not to fulfill to all the requirements demanded in the actuality, contribute to facilitate the work of the libraries in bigger degree of what the laws of the latin american countries, really deficient, in its great majority.