The lex loci delicti isn't always the US law, even for cases heard in the US. In London Film Productions, Ltd. v. Intercontinental Communications, Inc. (1984) a US corporation was sued by a British company for infringements under the laws of several Latin American countries; the US court determined that it had jurisdiction.[11]
In Bridgeman Art Library, Ltd. v. Corel Corp. (1998) a US court decided that the it must apply the stricter US threshold of originality (decided in Feist v. Rural) rather than the lower British standard invoked by the plaintiff.
A more complex case of determining ownwership under Russian law in a US court was Films by Jove Inc. v. Berov because it involved two claimants to copyrights under the Russian laws to films by Soyuzmultfilm, themselves involved in litigation in Russia. A US judge basically overruled a decision by the Supreme Court of Arbitration of Russia because, in his view, the Russian court's decision was "strongly influenced, if not coerced, by the efforts of various Russian government officials seeking to promote ‘state interests’",[12] thus lacking procedural fairness.[13]
In France, the Court of Cassation decided on 10 April 2013 that in case of conflicting laws, the French law prevails in all matters regarding copyright, including the determination of ownership. This ruling quashed the decision of a lower court, which had decided that in a lawsuit between a reporter-cameraman of a US media company operating in France, the US law applied in determining ownership of the footage.[14]