se of _Jeffreys_ v. _Boosey_ is not a binding authority in the
exposition of this later statute. The act appears to have been
dictated by a wise and liberal spirit, and in the same spirit it
should be interpreted, adhering of course to the settled rules of
legal construction. The preamble is, in my opinion, quite inconsistent
with the conclusion that the protection given by the statute was
intended to be confined to the works of British authors. The real
condition of obtaining its advantages is the first publication by the
author of his work in the United Kingdom. Nothing renders necessary
his bodily presence here at the time, and I find it impossible to
discover any reason why it should be required, or what it can add to
the merit of the first publication. If the intrinsic merits of the
reasoning on which, _Jeffreys_ v. _Boosey_ was decided be considered,
I must frankly admit that it by no means commands my assent."

These conclusions might follow also from the Naturalization Act of 1870,
which enacts that real and personal property of every description may be
taken, acquired, held, and disposed of by an alien in the same manner in
all respects as by a natural born British subject. At the present time
the International Copyright Act has largely removed the question from
the area of conflict.

The Bern Convention.

14. _International Copyright._--Books published in one country and
circulated in another depend for their protection in the latter upon
international copyright. Until 1886 international copyright in Great
Britain rested on a series of orders in council, made under the
authority of the International Copyright Act 1844 (superseding acts of
1820 and 1826), conferring on the authors of a particular foreign
country the same rights in Great Britain as British authors, on
condition of their registering their work in Great Britain within a year
of first publication abroad. A condition of the granting of each order
was that the sovereign should be satisfied that reciprocal protection
was given in the country in question to British authors. As the result
of conferences at Bern in 1885 and 1887, this system was simplified and
made more general by the treaty known as "The Bern Convention," signed
at Bern on the 5th of September 1887. The contracting parties were the
British Empire, Belgium, France, Germany, Italy, Spain, Switzerland,
Tunis and Hayti. Luxemburg, Monaco, Norway and Japan aft