Wednesday, September 28, 2005

Transformative Use Justifies GooglePrint Scans of Entire Books as Fair Use

As is clear from our previous posting, the lawsuit by Author's Guild against Google turns - in our opinion - on the issue of non-infringing "transformative use" (something that Judge Posner (see further below), e.g. calls "complementary copying"). This is opposed to infringing "superseding use" (which e.g. Judge Posner calls "substitutional use").

The transformative use to which GooglePrint (viz. Google Print) converts its scans of library holdings - in our opinion - justifies scans of entire books in libraries as fair use. We think that is the major legal issue in this case.

We find that James DeLong (short bio) at IPcentral has framed that issue best in compact form as follows in his September 21, 2005 posting:

Google's response to the Authors Guild lawsuit is:
We regret that this group chose to sue us over a program that will make millions of books more discoverable to the world -- especially since any copyright holder can exclude their books from the program. What’s more, many of Google Print’s chief beneficiaries will be authors whose backlist, out of print and lightly marketed new titles will be suggested to countless readers who wouldn’t have found them otherwise.
It adds:
Let's be clear: Google doesn’t show even a single page to users who find copyrighted books through this program (unless the copyright holder gives us permission to show more). At most we show only a brief snippet of text where their search term appears, along with basic bibliographic information and several links to online booksellers and libraries.
Under the last paragraph, the issues are fascinating. To show only the limited info described by Google would, IMHO, pretty clearly be a fair use. So the authors must be objecting to the fact that an entire book is being copied without permission, even if it is then hidden in an electronic vault. But what is the objection, if only snippets are shown? Is it a fear of Napsterization -- that once the digital copy is made it could escape into the world? Or is it simply a naked assertion of right -- "copyright law says no copying, so you must pay me to do it, even if it would actually be in my interest to have snippets made available."

Applying the logic of the reasoning used by Judge Thomas G. Nelson of the Ninth Circuit Appeals Court for the ruling in Kelly v. Arriba Soft Corporation, the provision of such "snippets of text" by search engines is analogous to the provision of "thumbnails of graphics", which was found to be fair use in Kelly v. Arriba.

Kelly v. Arriba also found that:

[A]lthough Arriba did copy each of Kelly’s images as a whole, it was reasonable to do so in light of Arriba’s use of the images. It was necessary for Arriba to copy the entire image to allow users to recognize the image and decide whether to pursue more information about the image or the originating web site. If Arriba only copied part of the image, it would be more difficult to identify it, thereby reducing the usefulness of the visual search engine.

Similarly, of course, GooglePrint could not provide accurate, truly informational snippets of text as search results if they did not scan books in entirety. Hence, in our view, the permissible transformative use engaged in by GooglePrint also permits the copying (scanning) of entire books as "reasonable" "in light of [their] use of the [snippets].

The fact that Google permits copyright owners to opt-out of the library scanning and listing project is irrelevant to the direct copyright issue, since transformative use requires no permission from the copyright owner.

However, the opt-out alternative for copyright owners is relevant indirectly to the fair use copyright issue since it demonstrates "good faith" on the part of Google, which is not trying to infringe copyright material but rather to use already published material in a permissible transformative manner.

In our view, the Author's Guild has little chance to win this lawsuit, but then again, the judges decide. That's their job.

Update, 28 September 2005

Useful Websites on the Fair Use Issue

Stanford Copyright & Fair Use

Berkeley Copyright and Intellectual Property Rights

Cornell Legal Information Institute

Case Law

New York Times Co. v. Tasini, 533 U.S. 483 (2001), affirming 206 F.3d 161 (2d Circ. 2000).(inclusion of individual freelance copyrighted works in databases which permit complete access to the full text of such copyrighted articles). The copying in GooglePrint is to be clearly distinguished from the inclusion of copyrighted works in databases which then offer the copyrighted works in whole to the public, which is quite clearly a copyright infringement. Tasini clearly decided the issue that electronic RE-PUBLICATION of copyrighted works is a right which belongs to the copyright-owning authors. GooglePrint does not however involve electronic republication of such works. The sole issue in GooglePrint is whether Google can scan published copyrighted works for use in information search through "text snippets". That is an entirely different legal question.

Harper & Row, Publishers, Inc., et al. v. Nation Enterprises et al., 471 U.S. 539; 105 S. Ct. 2218; 85 L. Ed.2d 588; 53 U.S.L.W. 4562 (1885) (use of excerpts totalling 13% of an unpublished manuscript). The case is found at FindLaw and BitLaw.

Ty, Inc. v. Publications International Ltd., 292 F.2d 512 (7th Cir. 2002). Probably the best treatment by a judge of the fair use exception is found in Judge Posner's opinion in this case where he writes about book review citations from books as being "permissible" fair use, inter alia because they "serve the reading public as a useful guide" . We would find such book review citations as comparable to Google's "snippets" as "guides" for the public. Posner writes:

"The defense of fair use, originally judge-made, now codified, plays an essential role in copyright law. Without it, any copying of copyrighted material would be a copyright infringement. A book reviewer could not quote from the book he was reviewing without a license from the publisher. Quite apart from the impairment of freedom of expression that would result from giving a copyright holder control over public criticism of his work, to deem such quotation an infringement would greatly reduce the credibility of book reviews, to the detriment of copyright owners as a group, though not to the owners of copyright on the worst books. Book reviews would no longer serve the reading public as a useful guide to which books to buy. Book reviews that quote from ("copy") the books being reviewed increase the demand for copyrighted works; to deem such copying infringement would therefore be perverse, and so the fair-use doctrine permits such copying. Desnick v. American Broadcasting Companies, Inc., 44 F.3d 1345, 1351 (7th Cir. 1995) (dictum); William M. Landes, "Copyright, Borrowed Images, and Appropriation Art: An Economic Approach," 9 Geo. Mason L. Rev. 1, 10 (2000); Lawrence Lessig, "The Law of the Horse: What Cyberlaw Might Teach," 113 Harv. L. Rev. 501, 528 (1999). On the other hand, were a book reviewer to quote the entire book in his review, or so much of the book as to make the review a substitute for the book itself, he would be cutting into the publisher's market, and the defense of fair use would fail. Harper & Row, Publishers, Inc. v. Nation Enterprises, 723 F.2d 195, 215 (2d Cir. 1983) (dissenting opinion), rev'd, 471 U.S. 539 (1985); see Harper & Row, Publishers, Inc. v. Nation Enterprises, 471 U.S. 539, 562 (1985); Worldwide Church of God v. Philadelphia Church of God, Inc., 227 F.3d 1110, 1118 (9th Cir. 2000); Consumers Union of United States, Inc. v. General Signal Corp., 724 F.2d 1044, 1051 (2d Cir. 1983).

Generalizing from this example in economic terminology that has become orthodox in fair-use case law, we may say that copying that is complementary to the copyrighted work (in the sense that nails are complements of hammers) is fair use, but copying that is a substitute for the copyrighted work (in the sense that nails are substitutes for pegs or screws), or for derivative works from the copyrighted work, see 4 Melville B. Nimmer & David Nimmer, Nimmer on Copyright sec. 13.05[B][1], p. 13-193 (2002), is not fair use. On Davis v. The Gap, Inc., 246 F.3d 152, 175-76 (2d Cir. 2001); Suntrust Bank v. Houghton Mifflin Co., 268 F.3d 1257, 1277 (11th Cir. 2001) (concurring opinion); Wendy J. Gordon, "Fair Use as Market Failure: A Structural and Economic Analysis of the Betamax Case and Its Predecessors," 82 Colum. L. Rev. 1600, 1643 n. 237 (1982); see Consumers Union of United States, Inc. v. General Signal Corp., supra, 724 F.2d at 1051. If the price of nails fell, the demand for hammers would rise but the demand for pegs would fall. The hammer manufacturer wants there to be an abundant supply of cheap nails, and likewise publishers want their books reviewed and wouldn't want reviews inhibited and degraded by a rule requiring the reviewer to obtain a copyright license from the publisher if he wanted to quote from the book. So, in the absence of a fair-use doctrine, most publishers would disclaim control over the contents of reviews. The doctrine makes such disclaimers unnecessary. It thus economizes on transaction costs.

The distinction between complementary and substitutional copying (sometimes--though as it seems to us, confusingly--said to be between "transformative" and "superseding" copies, see, e.g., Campbell v. Acuff-Rose Music, Inc., 510 U.S. 569, 579 (1994)) is illustrated not only by the difference between quotations from a book in a book review and the book itself, Marion B. Stewart, "Calculating Economic Damages in Intellectual Property Disputes: The Role of Market Definition," 77 J. Patent & Trademark Office Society 321, 332 (1995), but also by the difference between parody (fair use) and burlesque (often not fair use). A parody, which is a form of criticism (good-natured or otherwise), is not intended as a substitute for the work parodied. But it must quote enough of that work to make the parody recognizable as such, and that amount of quotation is deemed fair use. Campbell v. Acuff-Rose Music, Inc., supra, 510 U.S. at 579, 580-81 and n. 14, 588; Suntrust Bank v. Houghton Mifflin Co., supra, 268 F.3d at 1271; Leibovitz v. Paramount Pictures Corp., 137 F.3d 109, 114 (2d Cir. 1998); Dr. Seuss Enterprises, L.P. v. Penguin Books USA, Inc., 109 F.3d 1394, 1400 (9th Cir. 1997); 4 Nimmer & Nimmer, supra, sec. 13.05[C], pp. 13-203 to 13-218....

Book reviews and parodies are merely examples of types of work that quote or otherwise copy from copyrighted works yet constitute fair use because they are complements of (though sometimes negative complements, as in the case of a devastating book review) rather than substitutes for the copyrighted original. The commonest type is simply a quotation from a copyrighted work in a book or article on the same or a related subject. The complementary effect may be quite weak, but the quotation is unlikely to reduce the demand for the copyrighted work; nor could the copyright owner command a license fee commensurate with the costs of transacting with the copier. Such copying is therefore fair use."

Concerning this case, see Ivan Hoffman and the Beanie Babies Collector's Guide.

Hoffman writes regarding the fair use cases:

"Thus, clearly there is a conflict between the rights of the copyright owner and the rights of the user of the material, as there is in any fair use case."

Posner writes in this regard in a later opinion in the case of Chicago Board of Education v. Substance, Inc. (7th Cir. 2003) as follows:

"So where to draw the line? The question cannot be answered precisely. The fair use defense defies codification. As we said in Ty, the four factors that Congress listed when it wrote a fair use defense (a judicial creation) into the Copyright Act in 1976 are not exhaustive and do not constitute an algorithm that enables decisions to be ground out mechanically. Ty, Inc. v. Publications Int'l Ltd., supra, 292 F.3d at 522; see also Campbell v. Acuff-Rose Music, Inc., supra, 510 U.S. at 577-78; Harper & Row, Publishers, Inc. v. Nation Enterprises, supra, 471 U.S. at 560. The general standard, however, is clear enough: the fair use copier must copy no more than is reasonably necessary (not strictly necessary—room must be allowed for judgment, and judges must not police criticism with a heavy hand) to enable him to pursue an aim that the law recognizes as proper, in this case the aim of criticizing the copyrighted work effectively. Ty, Inc. v. Publications Int'l Ltd., supra, 292 F.3d at 521; Kelly v. Arriba Soft Corp., 336 F.3d 811, 820-21 (9th Cir. 2003); Sundeman v. Seajay Society, Inc., supra, 142 F.3d at 206.

The burden of proof is on the copier because fair use is an affirmative defense, Campbell v. Acuff-Rose Music, Inc., supra, 510 U.S. at 590; Harper & Row Publishers, Inc. v. Nation Enterprises, supra, 471 U.S. at 561; Video Pipeline, Inc. v. Buena Vista Home Entertainment, Inc., 342 F.3d 191, 197 (3d Cir. 2003)...."

A closing comment: if the judges find against Google Print, they basically have to invalidate the entire process of search engine servers storing masses of online copyrighted material, the corpus of which they access in order to provide useful search results in "snippet" form. A decision for the Author's Guild would simply lead to internet search chaos, and that is not the role of the courts. They have to apply the law sensibly. Hence, we think Google Print will win.

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Author's Guild v. Google Print (GooglePrint)

With reference to our immediately previous posting, we have looked around the blogosphere for important opinions on the suit by the Author's Guild against Google and have found the following, to which we add our own grain of salt, as appropriate.

Lawrence Lessig at Lessig Blog comments:

"So too should common sense revolt at the claims of this law suit. I’m an academic, so this is a bit biased, but: Google Print could be the most important contribution to the spread of knowledge since Jefferson dreamed of national libraries. It is an astonishing opportunity to revive our cultural past, and make it accessible."

Eric Goldman in his Technology & Marketing Law Blog comments on the precedential case of Kelly v. Arriba Soft Corporation, writing:

The Ninth Circuit found that displaying thumbnail versions of photographs was fair use. The Ninth Circuit also originally found that displaying the full-size versions of the photos would not be fair use, although the Ninth Circuit (18 months later) realized that it had ruled on a question that neither party had litigated, and it withdrew that part of the opinion. The resulting mess of the case is so confusing and questionable as precedent that I don't teach the case in Cyberlaw."

However, in the view of LawPundit, the logic of the court's revised ruling in Kelly v. Arriba Soft Corporation on the "fair use" of thumbnail images by a search engine is in fact quite clear. We quote our excerpted version below, which omits original footnotes, although some of their relevant content is included by us in our own bracketed writing:

The Opinion filed February 6, 2002, slip op. 1953, and appearing at 280 F.3d 934 (9th Cir. 2002), is withdrawn. It may not be cited as precedent by or to this court or any district court of the Ninth Circuit....

T.G. NELSON, Circuit Judge
[delivered the opinion of the Court]:
A claim of copyright infringement is subject to certain statutory exceptions, including the fair use exception. This exception
[citing Dr. Seuss Enters., L.P. v. Penguin Books USA, Inc., 109 F.3d 1394, 1399 (9th Cir. 1997)] "permits courts to avoid rigid application of the copyright statute when, on occasion, it would stifle the very creativity which that law is designed to foster." The statute sets out four factors to consider in determining whether the use in a particular case is a fair use. [The four factors are: (1) the purpose and character of the use, including whether such use is of a commercial nature or is for nonprofit educational purposes; (2) the nature of the copyrighted work; (3) the amount and substantiality of the portion used in relation to the copyrighted work as a whole; and (4) the effect of the use upon the potential market for or value of the copyrighted work. 17 U.S.C. § 107.] We must balance these factors in light of the objectives of copyright law, rather than view them as definitive or determinative tests. We now turn to the four fair use factors.

1. Purpose and character of the use.

[This part of the opinion can be applied in the case of Author's Guild v. Google to the argument that Google's Google Print project constitutes copyright infringement because Google is a commercial enterprise. This argument does not hold. Transformative use is permitted, also by commercial enterprises.]

The Supreme Court has rejected the proposition that a commercial use of the copyrighted material ends the inquiry under this factor. Instead, [citing Campbell v. Acuff-Rose Music, Inc., 510 U.S. 569, 579 (1994)] "[t]he central purpose of this investigation is to see ... whether the new work merely supersede[s] the objects of the original creation, or instead adds something new, with a further purpose or different character, altering the first with new expression, meaning, or message; it asks, in other words, whether and to what extent the new work is transformative."

The more transformative the new work, the less important the other factors, including commercialism, become. There is no dispute that Arriba operates its web site for commercial purposes and that Kelly’s images were part of Arriba’s search engine database. As the district court found, while such use of Kelly’s images was commercial, it was more incidental and less exploitative in nature than more traditional types of commercial use. Arriba was neither using Kelly’s images to directly promote its web site nor trying to profit by selling Kelly’s images.

Instead, Kelly’s images were among thousands of images in Arriba’s search engine database. Because the use of Kelly’s images was not highly exploitative, the commercial nature of the use weighs only slightly against a finding of fair use. The second part of the inquiry as to this factor involves the transformative nature of the use. We must determine if Arriba’s use of the images merely superseded the object of the originals or instead added a further purpose or different character. We find that Arriba’s use of Kelly’s images for its thumbnails was transformative.

Although Arriba made exact replications of Kelly’s images, the thumbnails were much smaller, lower-resolution images that served an entirely different function than Kelly’s original images. Kelly’s images are artistic works intended to inform and to engage the viewer in an aesthetic experience. His images are used to portray scenes from the American West in an aesthetic manner. Arriba’s use of Kelly’s images in the thumbnails is unrelated to any aesthetic purpose.

Arriba’s search engine functions as a tool to help index and improve access to images on the internet and their related web sites....

This case involves more than merely a retransmission of Kelly’s images in a different medium.

Arriba’s use of the images serves a different function than Kelly’s use — improving access to information on the internet versus artistic expression.... Because Arriba’s use is not superseding Kelly’s use but, rather, has created a different purpose for the images, Arriba’s use is transformative.

The Copyright Act was intended to promote creativity, thereby benefitting the artist and the public alike. To preserve the potential future use of artistic works for purposes of teaching, research, criticism, and news reporting, Congress created the fair use exception. Arriba’s use of Kelly’s images promotes the goals of the Copyright Act and the fair use exception. The thumbnails do not stifle artistic creativity because they are not used for illustrative or artistic purposes and therefore do not supplant the need for the originals. In addition, they benefit the public by enhancing information-gathering techniques on the internet.

[Those above statements in the opinion support Google Print. Indeed, this is Google's strongest argument. Google Print actually promotes the INTENT of the Copyright Act.]

2. Nature of the copyrighted work.

[In the case of Google Print, the works to be scanned in libraries and to be listed on Google are published works which the copyright holders intended for public consumption. Accordingly, the public also has the RIGHT to be able to find these works and to discover what they are about using modern search methods, without this being a copyright infringement.]

[Citing A&M Records, 239 F.3d at 1016 (citing Campbell, 510 U.S. at 586)]
"Works that are creative in nature are closer to the core of intended copyright protection than are more fact-based works." Photographs that are meant to be viewed by the public for informative and aesthetic purposes, such as Kelly’s, are generally creative in nature. The fact that a work is published or unpublished also is a critical element of its nature. Published works are more likely to qualify as fair use because the first appearance of the artist’s expression has already occurred....

3. Amount and substantiality of portion used.

[In the case of Author's Guild v. Google, it would appear - according to the logic of Kelly v. Arriba Soft Corporation - that scanning of entire books is permitted if the purpose and character of use is transformative and such scanning is required to perform the permissible transformative use.]

[Citing Worldwide Church of God, 227 F.3d at 1118]
"While wholesale copying does not preclude fair use per se, copying an entire work militates against a finding of fair use." However, the extent of permissible copying varies with the purpose and character of the use. If the secondary user only copies as much as is necessary for his or her intended use, then this factor will not weigh against him or her. This factor neither weighs for nor
against either party because, although Arriba did copy each of Kelly’s images as a whole, it was reasonable to do so in light of Arriba’s use of the images. It was necessary for Arriba to copy the entire image to allow users to recognize the image and decide whether to pursue more information about the image or the originating web site. If Arriba only copied part of the image, it would be more difficult to identify it, thereby reducing the usefulness of the visual search engine.

[That same logic applies to books and finding the material presented in them.]

4. Effect of the use upon the potential market for or value of the copyrighted work.

[There may be individual cases unknown to us where the scanning and listing of works on search engines might harm the potential market for or value of a copyrighted work, but 99% of all published works would not be harmed in their potential market or value in any way. Indeed, a good percentage of authors would find that the potential market or value of the copyrighted work would increase because Google Print would provide the opportunity that their works - and especially the content of those works - be findable by the public.]

This last factor requires courts to consider [citing Campbell v. Acuff-Rose Music, Inc., 510 U.S. 569, 590 (1994), quoting 3 M. Nimmer & D. Nimmer, Nimmer on Copyright § 13.05[A][4] (1993)] "not only the extent of market harm caused by the particular actions of the alleged infringer, but also 'whether unrestricted and widespread conduct of the sort engaged in by the defendant . . . would result in a substantially adverse impact on the potential market for the original.'" A transformative work is less likely to have an adverse impact on the market of the original than a work that merely supersedes the copyrighted work.... Arriba’s use of Kelly’s images in its thumbnails does not harm the market for Kelly’s images or the value of his images. By showing the thumbnails on its results page when users entered terms related to Kelly’s images, the search engine would guide users to Kelly’s web site rather than away from it....


We hold that Arriba’s reproduction of Kelly’s images for use as thumbnails in Arriba’s search engine is a fair use under the Copyright Act."

Scrivener's Error points out accurately that the actual copyright to most trade books still resides with the author but then goes forward to make the error in thinking that Google's opt-in or opt-out option has any major relevance for the judicial decision in this case. It does not. The major question is whether Google's scanning of library books for the purposes of listing such books on a search engine is a transformative use - and the answer can only be - yes, it is, depending upon how that material is presented online. The opt-in or opt-out function has merely to do with the time at which a copyright holder gives permission - which is in fact not even required for a transformative use.

William Patry has changed his mind from his original opinion at The Patry Copyright Blog after reading Jonathan Band's legal analysis in the interim. He writes at Google Revisited:

"So in the Google project, why should we care if there are server copies? The purposes for the copies in connection with the Print Library project is to give people access to knowledge about the existence of the book as well as a tiny amount of text. That is of great help to researchers and hopefully to authors and publishers of the books too. It in no way harms copyright owners unless the project becomes something else, namely a full-text service which then is a market substitute."

Such a change of heart can only be based on a better subsequent analysis of the applicable law, which, in our view, clearly favors Google.

Mike Madison at the Conglomerate writes:

"Books are really, really important things culturally, particularly in Western culture. Have been for hundreds of years. Almost everyone loves books and depends on books. And books are absolutely central to modern copyright law, both conceptually and doctrinally. (They're even more important than authors, in my view. But I'll take on one controversial topic at a time.) Books are fixed, limited containers of creativity. Books have beginnings, middles, and ends. Without books, we wouldn't have "works," and without "works" we wouldn't know how to process questions of incentives and questions of access. We wouldn't know where to put the author's "moral right," if there is one; we wouldn't know what to refer to when we make "fair use" of a work. We wouldn't know what to distribute, and distribution of creativity is the ultimate goal of the whole system."

Susan Crawford blog writes:

"Get interested in GooglePrint. It's one of the best plans that Google has, and it needs to happen. No one is going to bring more books to the attention of the world -- and help more authors -- than Google. Here are all the reasons that we should applaud Google for going forward with GooglePrint, and all the reasons why Google will prevail in the (sadly) recently-filed lawsuit."

Solveig Singleton at IPcentral Weblog predicts that Google will settle the case. Our opinion is that Google would be idiots to give in. They are in the right.

This class action is a violation of the spirit of the Class-Action Fairness Act of 2005. Some few are trying here to profit at the expense of the rest of the authors of the country. No damage has been done and yet some authors already want to obtain damage payments of some kind. The Author's Guild has no right to try to represent copyright holders in a class action for a right which is individual to each copyright owner. The class action suit by the Author's Guild against Google is nothing more than an attempted preemption of that individual right of copyright. This is a far greater danger to copyright owners' rights than anything that Google is doing.

See also Scrivener's Error for a listing of errors in the Author's Guild class action complaint.

James DeLong at IPcentral Weblog observes:
"Google might well win a decision that copying a whole book so that individualized snippets can be made available is itself a fair use because it greatly reduces overall transaction costs in the society. I find this argument persuasive, though it would be interesting to hear the other side."

Andrew Raff at IPTA Blog in "Google, Publishers, Copies and "Being Evil" has a good overview of blog postings on this topic.

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