LEGAL REGULATION OF DIGITAL CONTENT AND INTERNET COPYRIGHT: UZBEKISTAN IN COMPARATIVE PERSPECTIVE

Abstract

The regulation of digital content and online copyright poses a layered challenge: substantive rights must be recalibrated for borderless distribution, intermediaries must be allocated calibrated duties, and enforcement must keep pace with technological change without curtailing legitimate expression. This article examines Uzbekistan’s evolving framework for digital content and copyright and situates it against four comparator regimes: the United States, the European Union, China, and the Russian Federation. It traces Uzbekistan’s alignment with international norms — accession to the Berne Convention in 2004 and to the WIPO Internet Treaties in 2019, followed by the 2021 statutory amendments — and assesses the gap between formal protection and effective enforcement. The comparative analysis identifies four distinct regulatory philosophies: the U.S. safe-harbour model under the DMCA, the EU shift toward platform accountability through the Digital Single Market Directive, China’s administrative-led enforcement, and Russia’s site-blocking regime. The article argues that Uzbekistan should pursue a calibrated middle path that combines a dedicated copyright notice-and-takedown procedure, due-process safeguards against overreach, statutory recognition of flexible user exceptions, and active support for legitimate digital markets.