Copyright law and organizing the Internet.

ABSTRACT

UNITED STATES INTELLECTUAL PROPERTY LAW, specifically that covering copyright, has important implications for American libraries. This article considers the following: fair use and the Internet; current and prospective law and electronic media, especially concerning interlibrary loan and online reserves; publishers and users; and the impact that copyright law has on the role of the library and the issue of free access.

INTRODUCTION

Did you know that every e-mail you write, every Web page you create, anything that you generate in a tangible form is automatically copyrighted by United States law--whether you officially register it with the U.S. Copyright Office or not (Bruwelheide, 1995, p. 7)? Because the readers of Library Trends tend to be those of us associated with libraries, probably, yes, you do know this. Yet copyright law, especially that associated with electronic communications, continues to be a quagmire from which it is difficult to extract oneself, one's employment environment (library), or one's patrons.

Copyright is a serious matter that carries implications for organizing the Internet from both the viewpoints of the owners and publishers of a work to the work's users. This article will discuss several strands within the dilemma of the Internet and copyright: the law, including fair use; public domain; the Digital Millennium Copyright Act; the Technology, Education, and Copyright Harmonization Act; the Sonny Bono Extension Act; owners and users of copyrighted works and how the library and its role with respect to access comes into play; what we as librarians can do to make intellectual property a "smoother sell" to those with whom we work; and other intellectual property issues that may impact our interpretations of copyright law. Indeed, copyright law and organizing the Internet is a conundrum.

CURRENT LAW

Below is a discussion of some important areas (for those of us in libraries) of the current copyright law, along with examples. (1)

Please note that, in reference to this article, all examples will include some use of the Internet.

Fair Use

Those who work with and/or study copyright are well aware of the vagueness within the law. It is never more clear/unclear than when determining how much one can reproduce from a copyrighted work before being considered in violation of copyright law. Section 107 of the 1976 Copyright Act states that the amount of material we borrow from a copyrighted work depends on four factors:

* Purpose and character of use,

* Nature of the work,

* Part being copied, and

* Work's marketability. (2)

These four fair use factors must all be in place for a portion of an item to be considered to fall under fair use restrictions.

The first of the four fair use factors, purpose and character of use, covers what the borrower wants to do with the copied material. "Copying for nonprofit, educational, or personal reasons leans in favor of fair use ..." (Butler, 2001, p. 35). Thus, if you are an academic librarian, sending a personal e-mail with a paragraph from Statistical Methods for the Social and Behavioral Sciences (Marascuilo & Serlin, 1988) to a group of interested statistics students, you should be all set with factor one!

The second fair use factor, nature of the work, deals with the characteristics of the work one wishes to copy; in other words, "whether the work is fact or fiction, published or unpublished" (Butler, 2001, p. 35). Nonfiction and published media is most likely to fit this second factor. Thus, the academic librarian above is still in compliance, since Statistical Methods is nonfiction and was published in the 1980s.

The part of the work being copied, the third fair use factor, is a little more subject to debate. While the less amount one copies, the better, this factor is measured both quantitatively and qualitatively. Generally speaking, quantity is based on how much needs to be copied to achieve the objective and how much such an amount is in comparison to the total of the original. In addition, there is the issue of quality. Here the "heart" of the work comes into play. The heart of a work can vary from a tiny slice of an item to a huge portion. Therefore, if one sentence is the "heart" of Statistical Methods, copying it can be in violation (Butler, 2001, p. 35). Luckily for our academic librarian above, this does not seem to be the case with this particular copying example.

The fourth fair use factor is concerned with the marketability of the work, should copying of it occur. Chances are that e-mailing a group of college statistics students a paragraph out of Statistical Methods will not affect the sales of this book negatively, so here again our academic librarian is probably safe.

Remember, if you are not sure if you are in copyright law compliance when borrowing, it is still best to contact the owner of the work for permission. (3)

Sonny Bono Copyright Term Extension Act (CTEA)

In an effort to maintain consistency between the United States and the other members of the Berne Convention, (4) in 1998 Congress passed the Sonny Bono Copyright Term Extension Act (CTEA). So named because Congressman Bono was working on this at the time of his death, CTEA extends the duration of copyright in the United States retroactively from the life of the author plus fifty years to the life of the author plus seventy years and, in the case of works for hire and those under a corporate ownership, from seventy-five to ninety-five years or one hundred twenty years (whichever comes first) (Hoffman, 2001; Wikipedia, 2003b). This act was challenged as unconstitutional (Eldred v. Ashcroft) and brought before the Supreme Court in 2002. In January 2003, the Supreme Court found it constitutional (Wikipedia, 2003a). For libraries providing information via the Internet, CTEA means that we will have to get copyright clearance for much of what our patrons request for a longer period of time.

Public Domain

If all materials created were in the public domain, there would be no need for copyright law and litigation. Public domain determines that the owner of a copyrighted work has given up that ownership to the general public to use in any way that it pleases. Thus, someone creating a Web page can access a public domain electronic clip art Web site; borrow a graphic; place this on another Web page; modify the object in size, or color, or by adding or subtracting characteristics, whatever--all without worrying about obtaining permission to borrow or create a derivative work. (5)

Media in the public domain does not need to state that it is so. However, without that statement, interpreting whether or not an item is in the public domain is a somewhat complicated activity. General interpretation is that content is in the public domain if it was published before 1923. Additionally, any work created after January 1, 1978, will be in copyright until seventy years after the death of the last author or one hundred twenty years from the date of creation (in the case of works-for-hire) (Gasaway, 2001; Project Gutenberg, 2002). For the years in between, things can get a little complicated. For example, works published between 1964 and 1977, if they have a copyright notice, have a twenty-eight--year copyright term with an automatic extension of sixty-seven more years. An informative table, entitled "When Works Pass into the Public Domain," by Lolly Gasaway is available at http://www.unc. edu/~unclung/public-d.htm. It explains the various rules of public domain in regard to the year an item was published.

For those librarians concerned with electronic interlibrary loan and online reserves, public domain can be a wonderful thing. There is then no need to search for owners of works, ask for permissions, etc.

Digital Millennium Copyright Act (DMCA)

According to Gretchen McCord Hoffman in Copyright in Cyberspace: Questions and Answers for Librarians (2001), the Digital Millennium Copyright Act (DMCA) has far-reaching effects on copyright law, in a number of areas ranging from electronic communications to international copyright law, to exemptions for library reproductions, to anticircumvention technologies, to distance education, among others. For example, the DMCA can provide protection for libraries that are online sex-vice providers (OSP) in the instance of copyright violations, if the library/ provider registers an agent and develops policies for notification and termination of the service use should copyright violations be discovered (Hoffman, 2001).

For those of us concerned with libraries and the Internet, the DMCA is difficult to summarize, and several articles could be written in this area alone. It is possible that this law may end up influencing libraries in such arenas as "services, research, website development, distance education, and Internet access" (Crews, 2000, p. 116). For the purposes of this particular article, the points below illustrate some of the ways that the DMCA may affect those of us in libraries in terms of the Internet.

Given the WIPO Copyright Treaties section of the DMCA,

* "[C]opyright owners [can] impose technological controls and other restrictions on the use of their works, and ... constrain the use of materials for research and teaching in a manner more restrictive than may be established under existing copyright law" (Crews, 2000, p. 117). Thus, the owner of a copyrighted Web page could attach charges or restrictions to the use of his/her work by a library, even if the library's use was under fair use.

* "[T]he restrictions [in the first point above] may not apply to particular classes of works and to particular persons, if the restrictions would 'adversely affect' the ability to make 'noninfringing uses' of those works, as determined by the U.S. Copyright Office";

* Libraries may circumvent protections if they are evaluating a work for prospective purchase;

* Every three years, the Librarian of Congress will "conduct proceedings to examine and review the effect of the restrictions on the availability and use of copyrighted works, especially for education and libraries";

* Reverse engineering and encryption research of software may take place in libraries (Crews, 2000, p. 117).

Under the Online Service Provider Liability section of the DMCA, libraries (if they are an OSP):

* May not be held liable for copyright infringement committed by those using their online services;

* Must remove or disable access to infringing media;

* Must adopt a policy terminating the service of those users who do not abide by copyright law;

* Need to designate an agent to deal with copyright infringements (Crews, 2000, p. 118).

Because there is so much in the DMCA that can influence libraries in terms of the Internet, whether it is as an online service provider, use of interlibrary loan, distance education, etc., it is best to study the DMCA to determine where it effects your specific library setting and how. (6)

Technology, Education, and Copyright Harmonization (TEACH) Act

While the TEACH Act only indirectly affects most libraries, it is mentioned here due to its currency as one of the newest of our copyright laws. In effect, the TEACH Act gives institutional users (faculty, staff, and students) more rights to use and borrow materials for use in distance education than those previously provided under the 1976 copyright law. The TEACH Act, which became law in the later part of 2002, provides for fair use portions of a variety of instructional works in a distance education setting, if the providing institution follows a number of rules. These rules include that the institution is educational, nonprofit and accredited; works copied are lawfully obtained; materials are required for instruction, etc. Prior to its passage, remote classrooms, such as those connected through online education, television, and other means, had very few rights in comparison to face-to-face classrooms. The TEACH Act does not provide for "digital delivery of supplemental reading materials" (Harper, 2002). Thus, in libraries, we will still need to abide by the fair use guidelines.

UCITA 

In early 2003, the American Bar Association rejected the Uniform Computer Information Transaction Act (UCITA, 2003). While this is good news for libraries nationwide, the fact that UCITA is actually contract law means that every state has the option of whether to pass it or not. Currently, only two states, Maryland and Virginia, have passed UCITA. UCITA is a controversial and confusing law for those of us in libraries and for our patrons. It is a threat to the fair use doctrine as it applies to electronic media in that it validates both shrink and click-wrap licenses and replaces copyright law with contract law, thus allowing users to "click away their fair use rights" (Hoffman, 2001, p. 55; Kunze, 2000). In simple terms, the passage of UCITA in a particular state could mean that a library which owns a book and computer software purchased as a package might find itself being able to lend out the book but not the corresponding software. This could affect not only regular library circulation but also interlibrary loan: "its consequence would be to preempt copyright law with un-negotiated contract law, that is, to replace user rights under the copyright law, such as fair use, with agreements to give up those rights that users never have the opportunity to negotiate" (Hoffman, 2001, p. 147).

Other

Currently in the House and Senate a variety of federal copyright legislation is waiting for discussion, support, passage into law, etc. While these acts represent possible future legislation, we only look in this article to copyright law as it currently stands. However, be aware of new legislation as it occurs by keeping current in professional print journals; online sources, such as those provided by the ALA Web site; and professional organizations.

OWNERS AND USERS: LIBRARIES AND INTERNET ACCESS

Interlibrary Loan (ILL)

Because no library is able to have everything that its patrons will need at every point in time, interlibrary loan (ILL) is necessary. In the past this involved either copying print material or sending the original and mailing these items to the receiving library through snail mail In the world of electronic communications, ILL can be much quicker (just scan and send the item electronically) and much more difficult (how do the sending and receiving libraries work within copyright guidelines, since electronic copying and sending may mean a minimum of four extra copies being available at one time)? (7)

[The use of a fax or scanner to transmit copyrighted material is resolved if the library only uses these tools as transmission devices] (Martin, 2003).

Section 108 of the U.S. Copyright Law works with ILL within certain lender and borrower limits. For example, a lending library may send only one copy of one article from a specific journal or periodical issue. (Patrons who wish for a copy of more than one article from a specific journal should purchase the journal issue, subscribe to the journal, or pay a copyright fee.) Additionally, the Commission on New Technological Uses of Copyrighted Works (CONTU) Interlibrary Loan Guidelines state that a patron may borrow up to five copies of articles (but no more) from a specific journal within a given year. Therefore, whether the transmission is electronic or print, there is a limit to how much may be borrowed. In addition, the borrowing library must certify that its requests fit within the CONTU guidelines and must retain records to that effect for at least three years. It is also possible for ILL to occur through the use of URLs to access posted articles or databases for which a library has a license (Besenjak, 1997, pp. 156-157; Martin, 2003).

Online Reserves

Electronic reserves are often viewed with unease by those working in academic, special, public, and many other library settings due to the potential for unrestricted access, piracy, and violation of the fourth fair use factor (marketability). While print reserves in many libraries are traditionally offered under the fair use guidelines, electronic reserves may provide users with the ability to transmit copies to others as well as printout copies of works that are still under copyright law. What does this mean for libraries--those providers of reserves? Well, it actually means a great deal. The library involved needs to develop a series of checks and balances to protect itself from copyright violation and litigation and to protect its users as well. This is done in a number of ways. What libraries should do in terms of materials, electronic reserve, and copyright is described below. Libraries need to:

* Check that the material they put on reserve, which is not owned by them (for example, it may have been provided by an instructor), has been obtained in a lawful manner;

* Obtain appropriate permissions, if necessary;

* Pay royalties as needed;

* Follow the fair use guidelines, if no permission has been sought;

* Limit access; (8)

* Put on reserve as little an amount of the material as is feasible to satisfy course and user needs;

* Include a reference section and copyright notice from the original work on the electronic reserve item;

* Keep works on electronic reserve as short a time as possible (for example, one semester per class);

* Avoid putting problem items on electronic reserve; (9)

* Limit use of audio and video streaming; (10)

* Link to databases, instead of scanning items, if library licenses or subscriptions permit this;

* Remove access to the work once the course is over (Hoffman, 2001; Martin, 2003).

Thus, online reserves can be an easy way to provide materials to patrons--under the proper guidelines.

MORE INTELLECTUAL PROPERTY ISSUES TO CONSIDER

Two other issues involving intellectual property and the Internet require some time at this point: privacy and piracy. While not actually part of copyright law, these two areas are influential to libraries working in an electronic, i.e., Internet environment. They are briefly covered below.

Privacy

"These ... illustrate the dilemma librarians face in protecting patron confidentiality. Because one reads controversial literature does not necessarily mean that one is a threat to national security or society" (Weiner, 1997). "Broadly defined, privacy is regarded as information about oneself that is kept from others. In the library setting, right to privacy refers to the lack of availability of information about oneself" (Winter, 1997). What this means, in the library/information-seeking setting, is that a patron's personal circulation records, online reserves, reference questions, Internet access, and interlibrary loan requests should not be available to more than those library personnel who need the information in order to provide the patron with what s/he needs. As early as 1939, the American Library Association "recognized the right to privacy ... in its Code of Ethics for Librarians" (Mitchell, 2003b). Mitchell (2003b) also states that "the right to privacy in a library is also implicit in the ALA's Library Bill of Rights, which guarantees free access to library resources for all users and opposes any limitations on the right to an individual's exercise of free expression.... Through the Library Bill of Rights and the Code of Ethics, librarians fight to protect patron privacy and preserve our democratic society."

The potential for concerns with privacy issues comes from three major areas: "1) protecting libraries records; 2) making patrons aware of records that others can create based on their interactions while on library computers or networks; and 3) requiring vendor partners to adhere to an appropriate level of privacy protection" (Mitchell, 2003a). Perhaps because new legislations, such as the U.S.A. Patriot Act, may disagree with the idea of privacy in American libraries, abuse to privacy appears to be growing. Thus, privacy remains another topic, besides copyright law, which affects patrons' use of and access to library materials.

Piracy

Piracy is a term used to identify the unlawful use or borrowing of a copyrighted item. It is in violation of copyright law. The term is most often used in connection with the illegal use or copying of computer software and is considered a felony (Simpson, 2001, pp. 9, 84). It can also be applied to such things as intercepting satellite video transmissions (p. 74). Like privacy, piracy is not actually regulated by copyright law, but it is a closely related issue.

WHAT SHOULD WE DO?

Given the discussion above, what should we do when confronted with Internet copyright infringement by our colleagues and/or clientele? Certainly, neither pointing out their lack of integrity or ignorance in obeying copyright law will be popular stances. However, there are some ways to make such instances win/win or, at least, learn/learn situations. We, as the copyright experts, can:

* Educate our audience through such venues as copyright workshops, in-services, classes, DVDs, videos, and teleconferences;

* Keep abreast of the most current changes in the law; (11)

* Be available for consultation by patrons and colleagues;

* Obtain support from those in our organization's administration;

* Be calm and understanding when confronting an infringement;

* Encourage correct action;

* Give examples of libelous actions and responses by the law to such actions;

* Cite law;

* Encourage users to read documentation;

* Encourage citing of information obtained from another source;

* Retain an intellectual properties attorney;

* Use original sources;

* Demonstrate ethical behavior;

* Remind our colleagues and clientele that we are all liable for our own actions.

CONCLUSION

In terms of copyright violations, ignorance is not bliss. This message alone is worth repeating to those who assume that because they are 1. educators, 2. not copying "much," 3. unable to find the owner of the work, 4. and other excuses, that they are not "really" in violation and/or will "never" get caught. While there are no "copyright police" commonly running from library to library, there are people willing to report violations and companies willing to pay for these reports (Butler, 2002, p. 42). Thus, it is imperative that those of us in libraries, whether working with patrons or behind the scenes, abide by copyright law.

NOTES

(1.) Caveat: This article covers the U.S. law and issues in using Internet materials published in the United States. International issues are a separate subject and will not be addressed here, unless needed for definition purposes.

(2.) Although for this article's purposes we are addressing the Internet, this discussion applies to all sorts of media, not just those accessible via the Internet.

(3.) Copyright permission information is not included in this article. A wide variety of print and electronic sources are available on this subject, however. The following references support such information: About SESAC, retrieved August 15, 2001, from http:// www.sesac.com/aboutsesac/aboutsesacl.html; American Society of Composers, Authors, and Publishers, retrieved June 26, 2001, from http://www.ascap.com/licensing/ about.html; ASCAP Licensing: Frequently Asked Questions About Licensing, (2001), retrieved June 25, 2001, from http://ascap.com/licensing/licensingfaz.html; Association of American Publishers, How to Request Copyright Permission from Publishers, (1998), retrieved June 25, 2001, from http://www.publishers.org/home/about a/highered/howtopg.htm; BMI and Performing Rights, retrieved August 15, 2001, from http://www.bmi.com/ licensing/; Brad Templeton, (n.d.), 10 Big Myths About Copyright Explained, retrieved June 25, 2001, from http://www.templetons.com/brad/copymyths.html; J. H. Bruwelheide, (1995), The Copyright Primer for Librarians and Educators, 2nd ed. (Chicago: American Library Association); Clearing the Way for Your Rights, (1999), retrieved June 26, 2001, from http://www.presentations.com/create/organiz/1999/06/31_fl_cop_04.html; Copyright Permission Letter, (1996), retrieved June 26, 2001, from http://www.bham.wednet.edu/ copyperm.htm; Fair Use: Obtaining Permissions, Georgia Harper, (1997), Sample Letter Requesting Permission, retrieved June 1, 2001, from http://www.utsystem.edu/ogc/intellectualproperty/permmm.htm; Fulcrum Publishing, (n.d.), How to Apply for Permission, retrieved June 25, 2001, from http://fulcrum-books.com/html/permissions.html; "Getting Permission," retrieved June 25, 2001, from http://www.utsystem.edu/ogc/ intellectualproperty/permissn.htm; Illinois Association of School Boards, (1999, February), General Personnel: Exhibit--Request to Reprint Material, 5.170-E: 1; Motion Picture Licensing Corporation, retrieved August 15, 2001, from http://www.mplc.com/ index2.htm; "Organizing Your Message: Getting Copyright Permission," retrieved June 26, 2001, from http://www.presentations.com/create/organiz/1999/06/31_fl_cop_04thtml; O'Reilly & Associates, Inc., (2001), Permission Guidelines, retrieved June 25, 2001, from http://www.oreilly.com/oreilly/author/permission/; R. S. Talub, (2001, May/June), "Permissions, 'Fair Use', and Production Resources for Educators and Librarians, Part I of II," TechTrends, 45(3), 8; Requesting Permission, (n.d.), retrieved June 25, 2001, from http://depts.Washington.edu/uwcopy/use/obtainingrights/5.shtml; "Zip Through Permissions as Never Before--Over the Web!" retrieved June 26, 2001, from http://www.copyright.com.

(4.) The Berne Convention is one of two major international copyright treaties (the other is the Universal Copyright Convention) to which the United States adheres. Because there is no common copyright law in the world, these two conventions' members agree to abide by and give each other the same copyright protection that is given in their own countries (Besenjak, 1997, p. 48).

(5.) This is, of course, assuming that the clip art site really is in public domain. It is possible for a site creator to claim that all clip art (or other works) are in public domain when, in tact, some or all of these items are borrowed from copyrighted sites (Butler, 2000).

(6.) The Digital Millennium Copyright Act can he found in full at http://www.loc.gov/ copyright/legislation/dmca.pdf. Another helpful site for libraries in terms of the DMCA and the Sonny Bono Copyright Term Extension Act is Arnold P. Lutzker's site, entitled "Primer on the Digital Millennium: What the Digital Millennium Copyright Act and the Copyright Term Extension Act Mean for the Library Community." It is found at http://www.arl.org/info/frn/copy/primer.html.

(7.) These extra copies could be 1. the copy scanned from the print version and placed on the hard drive of the library providing the copy; 2. the copy on the hard drive of the receiving library's computer; 3. the copy sent onward electronically to the patron; and 4. the copy the patron prints off of his/her computer.

(8.) Electronic access can be limited in a number of ways. For example, a library system may require a password from the user to enter the online reserve area. Access can also be limited with the use of class membership lists and/or retrieval by course number or the instructor's name (Martin, 2003).

(9.) "Problem" items might include student papers, unpublished pieces, course packs, textbooks, sample tests, etc. (Martin, 2003).

(10.) According to Charlie Morris in "Streaming Audio," http://wdvl.com/Multimedia/ Sound/Audio/streaming.html, audio and video streaming occur when audio and video files are able to play on your computer while you are still downloading them.

(11.) Professional journals and Internet sites for major library organizations, such as the American Library Association, represent excellent ways to remain current.

REFERENCES

Besenjak, C. (1997). Copyright plain & simple. Franklin Lakes, NJ: Career Press.

Bruwelheide, J. H. (1995). The copyright primer for librarians and educators. 2nd ed. Chicago: American Library Association.

Butler, R. P. (2000). Copyright and computers 2000. St. Charles, IL: Illinois Computing Educators Annual Meeting.

Butler, R. P. (2001). Copyright as a social responsibility: Fair use--I need it now! Knowledge Quest, 29, 35-36.

Butler, R. P. (2002). Software piracy: Don't let it byte you! Knowledge Quest, 31, 41-42.

Copyright law of the United States of America and related laws contained in Title 17 of the United States code. (2001). Circular 92.

Crews, K. D. (2000). Copyright essentials for librarians and educators. Chicago: American Library Association.

Gasaway, L. (2001). When works pass into the public domain. Retrieved February 10, 2003, from http://www.unc.edu/~unclung/public-d.htm.

Harper, G. (2002). The TEACH Act finally becomes law. Retrieved March 17, 2003, from http://www.utsystem.edu/ogc/intellectualpruperty/teachact.htm.

Hoffman, G. M. (2001). Copyright in cyberspace: Questions and answers for librarians. New York: Neal-Schuman Publishers.

Kunze, C. A. (2000). UCITA online: Uniform computer information transactions act. Retrieved March 19, 2003, from http://www.ucitaonline.com/.

Library of Congress. (2003). United States copyright office. Retrieved March 10, 2003, from http://www.loc.gov/copyright/.

Marascuilo, L. A., & Serlin, R. C. (1998). Statistical methods for the social and behavioral sciences. New York: W. H. Freeman.

Martin, R. (2003). The library and copyright issues. Presentation to ETT 590: Instructional Technology Workshop: Copyright. DeKalb, IL: Northern Illinois University.

Mitchell, K. (2003a). Privacy tutorial. Message #2. Chicago: American Library Association.

Mitchell, K. (2003b). Privacy tutorial. Message #4. Chicago: American Library Association.

Project Gutenberg Official Home Site. (2002). Public domain and copyright how-to. Retrieved February 10, 2003, from http://www.gutenberg.net/vol/pd.html.

Simpson, C. (2001). Copyright for schools: A practical guide, 3rd ed. Worthington, OH: Linworth Publishing.

UCITA Presentation. (2003). The "new" UCITA for 2003--Chapter relations/COL briefing. Philadelphia: American Library Association.

Weiner, R. G. (1997). Privacy and librarians: An overview. Retrieved March 11, 2003, from http://www.txla.org/puhs/tlj-1q97/privacy.html.

Wikipedia. (2003a). Eldred v. Ashcroft. Retrieved March 17, 2003, from http://www.wikipedia.org/wiki/Eldred_v_Ashcroft.

Wikipedia. (2003b). Sonny Bonn Copyright Term Extension Act. Retrieved March 17, 2003, from http://www.wikipedia.org/wiki/Sonny_Bono_Copyright_Term_Extension_Act.

Winter, K. A. (1997). Privacy and the rights and responsibilities of librarians. Retrieved March 11, 2003, from http://alexia.lis.uiuc.edu/review/winter1997/winter.html.

REBECCA P. BUTLER is an Associate Professor of Instructional Technology and School Library Media in the Department of Educational Technology, Research, and Assessment at Northern Illinois University, DeKalb. She is a former school library media specialist and has also worked in public, academic, special, and medical libraries. Her areas of research interest include intellectual properties, intellectual freedom, and the history of instructional technology. She writes a column on copyright law for Knowledge Quest, the journal of the American Association of School Librarians, and speaks nationally on intellectual property issues. She is currently finishing a book on copyright law.