Résumé

(his article provides a comparative analysis of the intellectual property (IP) frameworks governing Western comic books and Japanese manga, examining their structural, cultural, and legal distinctions. While the Western comic book industry—dominated by major corporate entities—relies heavily on the “work-for-hire” model, which centralizes economic ownership, the manga industry operates under a unique paradigm that balances the creator’s artistic moral rights with a complex system of editorial collaboration. The research explores how these divergent legal philosophies influence character ownership, derivative works, and the management of fan-driven dissemination, such as the doujinshi phenomenon. By evaluating how digital globalization and transmedia expansion challenge traditional copyright concepts, the study investigates whether these mediums function as market rivals or as distinct reflections of different cultural approaches to artistic creation. Through a comparative legal lens, the article concludes that the increasing convergence of global platforms necessitates a reassessment of current IP policies to better harmonize the protection of creators’ interests with the realities of modern, decentralized audience participation.