GBS: French Law or U.S. Law?

Regular French Google-blogger and -tweeter has an important blog post (Bing translation) on a very important decision by the Tribunal de Grande Instance de Paris on choice of law in a copyright lawsuit against Google. The case involved a Perfect 10-style scenario: unauthorized parties posted a copyrighted image that Google then automatically indexed. In a decision that appears to turn in part on the role of Google France and in part on the Frenchness of the author and the work, the court held that the appropriate copyright law to apply would be French, not American. As Callimaq notes, this case has substantial implications for the Google Book Search case.