The key differences are that they allow criminal punishment (such as this) though that’s not super common unless it’s egregious (like lots of money), this is pretty insane (though any criminal punishment for copyright violation is)
Registration is also automatic. In the us copyright is automatic as well but you have to register your copyright to sue for damages. In Japan this is not necessary, work is copy written upon creation and protections are granted without registration
The big one though vs us law is that they don’t have an exception for fair use. This is why manga and anime typically go to great (or minor) lengths to avoid saying names of products and chains. Unless they have a working relationship with the item/vendor/chain and explicit permission to do so they can be sued for having a character go to don quixote or whatever if donki decides their brand is damaged by being associated with some trashy manga.
Further complicated by the existence of doujin, which are all blatantly in violation of this system, but tolerated and even encouraged mainly because of cultural precedent. That said the doujin market is itself a complex and hypocritical beast filled with exploitation because of this. When works are small no one cares. When they are medium, free advertising. When they are too big to rival the brand it can cause issues and there has been precedent for shitty behavior here (shutdowns, poaching artists from circles, etc). Similarly disagreeable content can get you shut down (eg Pokémon and Nintendo banning sexualized doujin, kadokawa banning kantai collection doujin featuring rape, kodansha banning attack on titan doujin featuring “disagreeable political themes”)
copyright law is Japan is weird and very uncool
The key differences are that they allow criminal punishment (such as this) though that’s not super common unless it’s egregious (like lots of money), this is pretty insane (though any criminal punishment for copyright violation is)
Registration is also automatic. In the us copyright is automatic as well but you have to register your copyright to sue for damages. In Japan this is not necessary, work is copy written upon creation and protections are granted without registration
The big one though vs us law is that they don’t have an exception for fair use. This is why manga and anime typically go to great (or minor) lengths to avoid saying names of products and chains. Unless they have a working relationship with the item/vendor/chain and explicit permission to do so they can be sued for having a character go to don quixote or whatever if donki decides their brand is damaged by being associated with some trashy manga.
Further complicated by the existence of doujin, which are all blatantly in violation of this system, but tolerated and even encouraged mainly because of cultural precedent. That said the doujin market is itself a complex and hypocritical beast filled with exploitation because of this. When works are small no one cares. When they are medium, free advertising. When they are too big to rival the brand it can cause issues and there has been precedent for shitty behavior here (shutdowns, poaching artists from circles, etc). Similarly disagreeable content can get you shut down (eg Pokémon and Nintendo banning sexualized doujin, kadokawa banning kantai collection doujin featuring rape, kodansha banning attack on titan doujin featuring “disagreeable political themes”)