In case of physical manifestations, there is an ownership of the physical medium, and copyright rights are 'subservient' to ownership transfer/loan of mediu through 'first sale' doctrine.
For intangible copyright works (e.g. downloadable software), it is just contract and there is no transfer of ownership.
There is specific legislation that establishes 'first sale' doctrine for intangible software, but not for other copyright works.
The current situation is similar in the US, except for the extra enabling legislation. Copyright law was never intended to completely prevent the secondary market, because nobody envisioned technology that would make ownership transfer impossible without making copies— a consumer would always have an “original” that the author was paid for and could be given away freely.
In case of physical manifestations, there is an ownership of the physical medium, and copyright rights are 'subservient' to ownership transfer/loan of mediu through 'first sale' doctrine.
For intangible copyright works (e.g. downloadable software), it is just contract and there is no transfer of ownership.
There is specific legislation that establishes 'first sale' doctrine for intangible software, but not for other copyright works.
See https://www.lexology.com/library/detail.aspx?g=449a705d-d76a... (or http://archive.is/GZ6mX )