The ongoing row about the ACTA treaty has highlighted the differing ways that countries treat copyright infringement, revealing how hard it's going to be to get any sort of consensus. 

Take Germany, a country that has a rather unmerited reputation for heavy-handed laws. Earlier this week, justice minister Sabine Leutheusser-Schnarrenberger said in an interview with German news magazine Das Spiegel that the German government would never consider cutting off the internet connection in cases where users are being accused of downloading copyrighted material saying that "cutting off the Internet is the wrong way to deal with copyright infringement".

Compare and contrast that approach to the UK's Digital Economy Bill, which has just passed its reading in the House of Lords, thanks to a joint Liberal Democrat/Conservative amendment even more illiberal than the one proposed by the Labour government.  As digital rights body, The Open Rights Group has pointed out, the amendment means that ISPs faced with a demand from a copyright holder to either block or pay costs is going to choose the simpler option of blocking, regardless of whether the demand is a fair one or not.

This is not an isolated incident: the British parliament is following the lead set by the French government, which passed a "three strikes and you're out" law in May last year.

It's a really uninspiring spectacle: the three main parties all falling over themselves to be the most heavy-handed and sitting rather at odds with all parties' intention to make Internet access and broadband provision a key part of the UK economy revival.

The web isn't called the worldwide web for nothing and the differing attitudes between the different national governments serves only to remind us that national borders don't seem to matter any more. We've already seen in Russia and China how government attitudes to cybercrime and cyberterrorism can breed particular cultures and it's not too much of a leap to see how different government attitudes to copyright will lead to a split in how websites are managed - certainly, the idea that closing down a new users in the UK is going to stop copyright theft is a naive one.

No-one is saying that copyright holders should have no protection but there needs to be a balance between individual rights, between the develop of an Internet economy and the rights of copyright owners. Certainly, a measure that closes sites first and asks questions later is not the right approach.