Comparative legal characteristic of the character as an object of copyright in Russia, the USA and China

The article provides a legal description of the character of the work as a separate copyright object in the legal system of the Russian Federation, the USA and China using the methods of comparative jurisprudence. The legislation of all three countries considered does not specify the concept and characteristics of a character, however, in Russian legislation, the term “character” is mentioned directly in the Civil Code of the Russian Federation. In all three countries reviewed, detailed explanations regarding the character as a separate copyright object are provided in judicial practice. At the same time, it is noted that domestic judicial practice is more specific in comparison with the judicial practice of the United States, which at the same time covers some aspects of the character concerning certain individualizing elements of his image. Chinese judicial practice is generally similar to the American one, but it has some peculiarities concerning the connection of the central character of the work with other actors and the use of elements of his image. According to the results of the study, it is proposed to supplement the Russian legal regulation in terms of ensuring the protection of not only the character as a whole, but also its individual elements.