نوع مقاله : مقاله پژوهشی
موضوعات
عنوان مقاله English
نویسنده English
This comparative study examines the civil liability of Access Providers, Host Providers, and Content Providers under Iranian and German law. The main objective of this research is to analyze the legal differences and similarities between the two legal systems concerning the responsibilities of internet service providers for the dissemination and management of content in the digital space. In Germany, the liability of internet service providers is regulated by the Telemedia Act (TMG) and the E-Commerce Directive (EC-RL). According to Section 8 of the TMG, Access Providers are generally exempt from liability as long as they do not alter or store the transmitted data. Host Providers, under Section 10 of the TMG, must immediately remove illegal content once they become aware of it. In contrast, Content Providers bear full responsibility for the content they create and distribute, as they are considered the direct authors of such content. In Iran, similar laws, such as the Computer Crimes Law and the Electronic Commerce Law, regulate the liability of internet service providers. However, differences in practical implementation and enforcement exist, especially regarding how liability is pursued. This study aims to demonstrate how both countries adapt their legal frameworks to the challenges of the digital world and how the responsibilities of internet service providers are managed in an increasingly connected world.
کلیدواژهها English