A PRACTICAL GUIDE TO COPYRIGHT
by ADRIAN DURLESTER
Parnasa (livelihood) is a basic concept in Judaism. Our faith has long recognized that, while one can and should perform religious services such as writing liturgically-based music, performing cantorial or songleading services, etc., for the community willingly, people do need to earn a living. To varying degrees, composers, songwriters, and performers depend on income from legitimate sales of printed music and recordings.
"One who derives benefit and the other suffers loss [is liable]." (Bava Kamma 20a)
Another honored concept in Judaism is attribution. It is considered a great honor to report the words of another.
"R. Eleazar further said in the name of R. Hanina: Whoever reports a saying in the name of its originator brings deliverance to the world..." (Talmud Megilah 15a)
It is so important for Jewish organizations and institutions to show due respect to the creators and performers of Jewish music. This respect comes in the form of only performing authorized duplication of printed music, recordings, and other works; through properly attributing all works to their creators, and following the copyright law as it exists at this time.
The creators of contemporary Jewish music want their music to be used, and all encourage the use of their compositions. It is not the intent of Transcontinental Music, the ACC, JLicense, and the URJ to impose undue hardship or restrictions that would hinder the use of original works for worship, camps, schools, and other settings. Rather, we hope to find a way to balance the organizational need for fiscal responsibility using limited financial resources with appropriate respect for the artists' need for parnasa, and for being properly known as the creator of their works.
This FAQ is divided into two sections. The first contains practical answers to questions that might arise for you or your organization in your everyday activities. The second covers the underlying values and mechanisms of copyright and intellectual property law.
Section I: Practical FAQs
→What is best practice for me (or my organization) regarding copyright?
Both morally and legally, best practice would be to plan your activities and actions to be in compliance with copyright law. The cardinal guideline is to “ask permission.” Most composers, songwriters, publishers, et al are happy to work with you to help you get the permissions you need in a reasonable fashion. However, copyright holders are likely to be more receptive when requests are made in a timely manner. All of that said, JLicense takes care of many typical issues.
→What if I am faced with a special situation and there’s no time to ask?
The answer is there’s always time to ask. Poor advance planning on your part does not create an automatic emergency for the copyright holder. Plan ahead. If you can’t get the permissions you need, select a different work for which you can, or find another suitable alternative.
→Can I make a copy of a copyrighted CD, DVD, or purchased audio or video file?
As a purchaser of the audio CD or download (no matter the content), you (or your institution) have the right to make one copy for your reference or back-up needs, unless you have received written permission from the publisher or copyright holder. Therefore, if you require multiple copies for a learning center, members of a group or any other use, you must by law purchase exactly the appropriate number of CDs or downloads. You may not distribute (or rent) your legal copy – it is for your own use. However, you may copy the content onto whichever format you choose – digital or otherwise, as long as it is for your own personal use.
By the “first sale” doctrine, you, as the initial purchaser of a sound recording may sell or otherwise dispose of that recording. When you do so, you must relinquish or destroy any backup copy you legally made for yourself. The person or entity which now has the recording is under the same copyright restrictions as the initial purchaser. You can “donate” your recording to your synagogue - and they can make one copy for their own reference or backup needs. They cannot make any additional copies.
JLicense allows you to distribute recorded music from our Member Composers and Publishers, for practice and rehearsal purposes.
→Can I live stream a worship service that includes copyrighted music and text?
You must obtain written permission or licensing from the copyright holder to do so. The “religious exemption” of Section 110 (3) does not cover this. A JLicense includes streaming rights.
→Can I record a worship service that includes copyrighted music for future broadcast or podcast?
You must obtain written permission or licensing from the copyright holder to do so or obtain a JLicense for your institution. The “religious exemption” of Section 110 (3) does not cover this.
→Can I record a children's/youth/teen choir performance at a service and upload the recordings to Facebook, You Tube, or similar social media?
You must obtain written permission or licensing from the copyright holder to do so or obtain a JLicense for your institution. The “religious exemption” of Section 110 (3) does not cover this.
→Can I create a songster or shiron for my congregation?
You must obtain written permission or licensing from the copyright holder to do so. This requires obtaining permissions from every copyright holder. JLicense does not currently provide an option for this.
→Can I create and use my own arrangements of a copyright song?
Creating an arrangement of any copyrighted song requires written permission or licensing from the copyright holder. The “religious exemption” of Section 110 (3) does not cover this. JLicense makes it easy to do so legally.
→Can I create slides or otherwise project lyrics to copyrighted songs at worship services? At other activities? At camp?
You must obtain written permission or licensing from the copyright holder to do so. The “religious exemption” of Section 110 (3) does not cover this. JLicense makes it easy to do so legally.
→Can I include and distribute lyrics to copyrighted songs on printed song sheets, service bulletins, etc. at worship services? At other activities? At camp?
You must obtain written permission or licensing from the copyright holder to do so. JLicense makes it easy to do so legally.
→Can I make copies of music for use by my accompanist or members of our band, choir, or other ensemble?
You are required to purchase a sufficient number of copies of each piece for each person requiring a copy of the music.
→Can I make photocopies of choir music?
Photocopying of copyrighted works is prohibited without written permission from the copyright holder. For “out of print” music you should contact the publisher for permission and to negotiate a fee. For music purchased as a downloadable and printable file, you are limited to making the number of copies you have licensed/purchased.
→Can our choirs perform music outside of worship services without permission?
Performing music outside of worship services, including recitals and concerts requires a license or written permission from the copyright holder. Some choral publishers do include performance rights as part of the purchase of a sufficient number of copies. If public performance rights are included, this will clearly be indicated on the music or the purchase agreement/receipt.
→Can I record a choir performance?
Written permission or license from the copyright holder is required.
→Can I make CDs or DVDs of recordings of performances?
Written permission or license from the copyright holder is required. You can make archival recordings.
→Can I make a rehearsal tape, or section/part rehearsal tapes?
Either a license or written permission from the copyright holder is required. JLicense makes this simple.
→What about items that are out of print?
Most publishers are agreeable, under special circumstances, to allow reproducing out-of-print items, but again, permission must be secured from the copyright owner prior to any duplication.
→Can I use copyrighted music as background for a video or slide presentation?
You cannot use copyrighted music as background music for a video or slideshow without obtaining what are known as “sync” rights which must be obtained from the copyright holder. "Sync" rights are not compulsory and the copyright holder can refuse to grant them.
→When is making a copy of a published and copyrighted print product (book, sheet music, etc.) legal, and when is it not?
Copying an entire book is never legal, unless: 1. You are given written permission from the publisher; 2. You are an educational institution copying sections of the work, with written permission from the publisher; 3. You are making one copy for your own records without distributing it.
→Why can’t I copy anything I want?
It’s against the law, other than in very specific circumstances, to make unauthorized copies of copyrighted materials.
→What about photocopies that are now in our synagogue / school / library?
Destroy any unauthorized photocopies immediately. Replace them with legal editions.
→Can I make copies of copyrighted music first and then ask permission?
No. Permission must be secured prior to any duplication.
→What about an emergency situation?
Under certain circumstances, photocopying music in emergency situations could be considered fair use. For example, if a student in your choir forgot or lost their music for the performance, making a copy for them to use could be considered fair use.
→What if I can’t find the owner of a copyrighted song. Can I go ahead and copy it without permission?
No. You must have the permission of the copyright owner, Check the copyright notice on the work, and/or check with the publisher of the collection in which the work appears. Once you have this information, write to the copyright owner.
→As a soloist, is it permissible for me to make a photocopy of a copyrighted work for my accompanist?
No. Permission for duplication, for any purpose whatsoever, must be secured from the copyright owner. It’s likely easier to purchase an additional copy for your accompanist.
→Is it permissible to print words only on a one-time basis, such as in a concert program?
No. Permission must be secured prior to any duplication. Using ‘just the words’ makes no difference. JLicense makes this easier and legal.
→Can I make a transparency of a copyrighted song for use by an overhead projector?
No. The making of a transparency is a duplication, and permission must be secured from the copyright owner.
→Can I make a record or tape using a prerecorded instrumental accompaniment track?
Two permissions are necessary here. One is from the copyright owner of the selection to be recorded, and the second is from the producer/manufacturer of the original record.
→Can I make a band arrangement of a copyrighted piano solo, or, can I make a flute arrangement of a copyrighted work for clarinet?
No. Making any arrangement is a duplication, and permission must be obtained from the copyright owner or with JLicense.
→What is a statutory or compulsory license?
For phonorecords (sound recordings and their derivative and subsequent media forms,) copyright reserves most rights for the copyright holder. One notable exception is the compulsory license. Once a copyright holder has “published” their song on a phonorecord and distributed that recording to the public (even at no cost) then anyone else who wishes to produce and distribute for private use their own recording of that work, they can do so simply by paying a set fee to the copyright holders. The copyright holder cannot object. (In simpler words, one can record a “cover” of a song just by paying a statutorily-established fee to the copyright holder.) This only applies to making a “cover” recording of a song. One can arrange the song to the “extent necessary to conform it to the style or manner of interpretation of the performance involved” but the arrangement “shall not change the basic melody or fundamental character of the work, and shall not be subject to protection as a derivative work … except with the express consent of the copyright owner.” You don’t have to use a compulsory license to record a cover, and can negotiate directly with the copyright holder if you choose. Note that this only applies to a cover recording. It does not grant any other rights. It doesn’t give you permission to do anything but create and distribute a cover recording of the song. You can’t create and print notated music, make a printed arrangement, project lyrics, perform the song live, etc. The compulsory license is meaningful for a songwriter or performing/recording artist, and not particularly meaningful for anyone else. (A compulsory license won’t help for that cover you record and post on YouTube.)
→What about all those "covers" on YouTube?
All of them technically require permissions from the copyright holder - both for the music, and the “sync” rights to use it with video. Some copyright holders are happy to see covers of their songs done by fans and others, and see it is just more promotion for their work. Others are more protective and may ask YouTube to take down the video. The best thing to do is to always seek permission. (Note, there are some artists who use Creative Commons and other methods to grant others the right to use their materials freely subject to certain restrictions.) If you’d like to make it easier for people to use your creations, consider using a Creative Commons license. For more information, visit https://creativecommons.org/
→What about the photocopiers who don’t “get caught”?
They force the price of legal editions higher. They enrich the manufacturers of copying machines at the expense of composers, authors, publishers and music retailers. They risk embarrassment from professional colleagues who understand the law; and they risk fines and jail sentences if taken to court. Frankly, we cannot imagine what kind of school, synagogue or professional musician would derive satisfaction from being a thief. Remember, any use of a copyrighted work for any purpose- for synagogue, for school, for a non-profit organization- to be sold, to be rented-for seemingly appropriate reason like-“just for our synagogue” –” words only”-“we’re not selling copies” – “emergency use” – “failure to locate the owner” – or any other reason or justification- requires permission BEFORE any duplication or copies can be made
→Shouldn’t religious institutions be exempt from copyright laws due to their nature and purpose?
The primary documents of American democracy help ensure that no preference is shown to a particular religion. The desire to maintain this balance between affairs of state and religious matters has limited Congress’ interest in affording religious institutions special treatment in enacted legislation. Instead, usage of Fair Use provisions, equally available to all, is relied upon. In Judaism, some of the fundamental principles underlying halacha regarding intellectual property are based on the desire to encourage the continued creation of commentaries on Torah and other works. Typically, Judaism incorporates opposing viewpoints on how best to do this. One school suggests this is done by insuring that creators are protected to insure they receive fair compensation for their works, thus encouraging to continue doing so. Another school simply suggests that the more Torah, the more Torah, and is thus reluctant to do anything that restricts such work. Western law practice has generally followed the former approach. The advent of modern technologies has occasioned a rise on the part of the latter camp through anti-copyright advocates who urge a range of reforms from modifications of present laws to complete elimination of copyright protections. Historically, a great deal of Western music had it origins in music written for use in churches. Recognizing that service to a higher purpose does not always provide adequate sustenance, church composers and musicians were fairly compensated for their services.
→What about “Fair Use?”
U.S. copyright law provides that reproduction "for purposes such as criticism, news reporting, teaching (including multiple copies for classroom use), scholarship, or research" is not an infringement of copyright. The law lists the following factors, which courts must consider together in determining whether a particular use of a copyrighted work is a permitted "Fair Use," or is instead an infringement of the copyright:
the purpose and character of the use, including whether such use is of a commercial nature or is for nonprofit educational purposes: the noncommercial educational use is more likely to be a fair use;
the nature of the copyrighted work: the more factual and less creative the work, the more likely it will be fair use;
the amount and substantiality of the portion used in relation to the copyrighted work as a whole: the more taken the less likely to be fair use; and
the effect of the use upon the potential market for or value of the copyrighted work: in other words, is the use taking away from the copyright owner money that the she might have been making from the work.
Courts look at all four factors in making a determination. Courts may choose to apply different levels of importance to any of the four factors in making their determination.
Citing "Fair Use" as a means of avoiding the effort to seek permission or license to copy, arrange, perform, or alter a copyrighted work is just not a sure bet. Courts apply the four factors on a case-by-case basis, and sometimes comes to different conclusions. “Fair Use” is a defense, not an excuse. The onus of proving fair use is on the person claiming it as a defense.
→What is the Jewish/Halachic perspective on Intellectual Property and Copyright?
Dina demalchuta dina (Talmud, Nedarim 28a) - This means literally, "the law of the government is the law", which means that, unless there are obvious Torah-based reasons for not doing so, we should follow the law of the land in which we live and work. The spirit and purpose of copyright legislation is the preservation of social justice and fairness, which falls clearly in line with Torah principles and Jewish ethics.
Zeh neheneh vezeh lo chaseir (Talmud, Bava Kamma 20a). This means: “One party is helped and the other is not harmed.” The teaching is that one who derives benefit through another person’s loss is liable to provide compensation. So someone could copy, if a) if it was generally true that selling and profiting from the sale of sheet music was not the convention for composers or publishers, or b) the composer or publisher lost nothing by it. Copying sheet music is clearly a violation of this Talmudic principle. Copying is not a victimless crime.
Hasagat gevul (Talmud, Bava Batra 21b and Tosafot, Kiddushin 59a): (‘illegal encroachment’) A person may not capitalize on the investment (in time, skill and resources) made by someone else – the profits are the exclusive right of the original ‘investor’. In this case, the investors in the creation of music are the composer and publisher; copying encroaches on and violates the creators’ business rights.
Shiur (Talmud, Bava Metziah, 34a): This is the principle of ‘retention’, by which an owner (or creator or composer in this case) can sell certain rights while retaining others. The convention in international law is that a composer (or publisher) sells the sheet music, but retains the exclusive rights to making copies of the music – which means that the buyer of the sheet music does not buy the right to make more copies.
Shalcha shali, v’shali shali, rasha (Pirkei Avot 5:10) - “The one who says ‘What is mine is mine, and what is yours is mine’ is wicked / selfish”. Someone who claims that they can freely copy a composer’s music is saying to the composer: “The sheet music that I bought is mine, and the rights to copying it are mine.” The first half of the statement is true, but the second half is untrue: copying rights are exclusively the composer’s and publisher’s.
Lo ta'amod al dam re'echa (Leviticus 19:16) "Do not stand idly by the blood of your neighbour." In copyright terms, we must not stand idly by and do nothing when we see a copy of sheet music being used; the composer and publisher are our neighbours. Are we happy to say and do nothing when we see someone stealing from them?
Limdu heiteiv dirshu mishpat, ashru chamotz (Isaiah 1:17): “Learn to do good. Seek justice. Correct the wrongdoers.” The composer and publisher are powerless to stop people copying sheet music, and loses out when they do. Are we going to do what we can to stop people doing it?
(The descriptions above are from “A Jewish Perspective on Copyright” by Alexander Massey, copyright 2013, licensed under Creative Commons CC BY-NC-ND 3.0)
In Judaism, some of the fundamental principles underlying halacha regarding intellectual property are based on the desire to encourage the continued creation of commentaries on Torah and other works. Typically, Judaism incorporates opposing viewpoints on how best to do this. One school suggests this is best done by insuring that creators are protected for a time to insure they receive fair compensation for their works, thus encouraging creators to continue doing so. Another school simply suggests that the more Torah, the more Torah, and is thus reluctant to do anything that restricts such work. A similar duality exists in modern times between proponents and detractors of existing copyright protections.
Copyright has been a much-contested issue in private business, government and educational institutions since the first strict laws were passed in the early 20th century. Following copyright law can be a tricky and confusing mire of exceptions and limitations, so we present to you here a simple guide to what you legally can and can’t do with Transcontinental Music Publications books and recordings.
Section II: Why Copyright?
→What is Copyright?
Copyright is an exclusive intellectual property right given to the creators of original musical, literary, and dramatic works. Broadly, copyright protects by law any asset or legal interest. And it provides the copyright owner the legal right to copy the work in any form, be it digital, print or recorded material.
→What is the basis of copyright in the United States?
Copyright is directly addressed in the United States Constitution, in Article 1, Section 8 (The Legislative branch, Powers of Congress)
The Congress shall have Power To…promote the Progress of Science and useful Arts, by securing for limited Times to Authors and Inventors the exclusive Right to their respective Writings and Discoveries;
In keeping with this Constitutional mandate, Copyright protection is provided by the laws of the United States (Title 17, U.S.Code) to the authors of “original works of authorship,” including literary, dramatic, musical, artistic, and certain other intellectual works. The first U.S. Copyright Act was passed in 1790. Updated acts were passed in 1831, and 1909, and then not again until 1976. Each subsequent act expanded the duration and scope of copyright protection. In 1988 the U.S. joined the Berne Convention. The 1998 Copayright Term Extension Act (The “Sonny Bono” Act) extended copyright duration to the current 95/120 years or life plus 70 years.) The 1976 Act remains the basic framework as adjusted by the 1988 and 1998 adjustments.
While publication rights were generally respected, historically, performance rights were not properly protected. Stephen Foster, the great American songwriter from the 1840-50s died a pauper because there was no formal system in place to insure that Foster was appropriately compensated whenever his music was performed. Just under 50 years later, composers Victor Herbert, Irving Berlin, Jerome Kern, John Phillip Sousa, and other prominent composers of the day founded ASCAP (American Society of Composers, Authors, and Publishers) the first U,S, performing rights organization (PRO.) (The story, perhaps apocryphal, is told that Victor Herbert got the idea to found ASCAP when he overheard someone performing one of his own pieces at a hotel where he was staying, and felt it was unfair that he hadn’t been compensated.)
Copyright protection is available to both published and unpublished works. Section 106 of the 1976 Copyright Act generally gives the owner of copyright the exclusive right to do and to authorize others to do the following:
reproduce the work in copies or phonorecords
prepare derivative works based upon the work
distribute copies or phonorecords of the work to the public by sale or other transfer of ownership, or by rental, lease, or lending
perform the work publicly, in the case of literary, musical, dramatic, and choreographic works, pantomimes, and motion pictures and other audiovisual works
display the work publicly, in the case of literary, musical, dramatic, and choreographic works, pantomimes, and pictorial, graphic, or sculptural works, including the individual images of a motion picture or other audiovisual work
perform the work publicly (in the case of sound recordings) by means of a digital audio transmission
→Is there an International Copyright Law?
No. Each nation is free to create its own intellectual property laws. However, in 1886, 10 nations gathered in Berne, Switzerland to create the Berne Convention for the Protection of Literary and Artistic Work. The Berne Convention created some minimum standards for copyright law protections and terms, but allowed individual states to establish laws above and beyond the minimums. The Convention calls for the laws of the country of the copyright holder to be recognized in cases of international disputes. The Convention has been updated and revised several times. The United States refused to join the Berne convention as it required too many changes to existing U.S. Copyright Law. Instead, the United States became a party to the competing Buenos Aires Convention in 1910, and later the Universal Copyright Convention in 1952. The United States did not become a signatory to the Berne Convention until 1988. The World Intellectual Property Organization Copyright Treaty (WIPO) was adopted in 1996 to address the issues raised by information technology and the Internet, which were not addressed by the Berne Convention. 172 nations (all 170 United Nations members, plus the Holy See and Niue) are now parties to the Berne Convention.
→Has Copyright Law kept pace with the digital age?
The answer to this question is a typically Jewish one: yes, no, and maybe. In 1996, WIPO was created to address new technologies not covered by the Berne Convention. The United States enacted the Digital Millennium Copyright Act in 1998. The primary purpose was to criminalize building devices or offering services intended to circumvent digital rights management (DRM) technologies. However, these laws, intended to deal with the realities of the times of AOL and Napster are not well-suited for the broadband, digital technologies of today. Congress has been slow to address the issues, and the government has been criticized for too often siding with larger corporate interests, big media companies, and the major PROs. Organizations like the Future of Music Coalition are fighting to give the average musician a seat at the table as new laws are drafted. There is also a significant anti-Copyright movement that insists that the First Amendment rights to freedom of expression supersede both corporate and individual artists’ needs for copyright protection of anything beyond a modest duration of seven to ten years. (Some anti-copyright advocates insist that copyrights should be abolished entirely.)
→How long does a copyright last?
In the United states, for works published after 1977, the copyright lasts for the life of the author plus 70 years, and registration is automatic. However, if the work is a work for hire (that is, the work is done in the course of employment or has been specifically commissioned) or is published anonymously or under a pseudonym, the copyright lasts 95 years from publication or 120 years from creation, whichever expires first. If the work was created, but not published, before 1978, the copyright lasts for the life of the author plus 70 years.
The copyright office provides this circular on copyright term:
All works published in the United States before 1923 are in the public domain
Originally, under the 1909 act, copyright lasted for 28 years and was renewable for a second 28-year term. Subsequent copyright acts added to and changed the lengths of these terms. As a result, works published after 1922, but before 1978 are protected for 95 years from the date of publication, IF the work was properly published with notice, and properly renewed after its initial term 28-year term. Any work published with notice between 1923-1968 that did not renew its original copyright is now in the public domain. (This makes ascertaining the copyright status of works published between 1923-1968 cumbersome because not all the records have been digitized and entered in a searchable database. You can find copies of scanned pages from the copyright renewal books online Though written for published books, this reference from a UPenn Library FAQ offers suggestions for researching copyright renewals:
The copyright office provides this circular on researching copyright status of a work. https://www.copyright.gov/circs/circ22.pdf
In Israel copyright in a work lasts for the life of its author (or longest surviving author, if there are multiple authors) plus 70 years, or 70 years from first publication if the work is anonymous or not credited. Sound recordings are protected for 50 years.
→What role does a copyright notice play?
Until 1989, a published work had to contain a valid copyright notice to receive protection under the copyright laws. But this requirement is no longer in force — works first published after March 1, 1989 need not include a copyright notice to gain protection under the law. These changes to U.S. Copyright Law were mandated when the U.S. became a signatory to the Berne Convention.
→What is the “Religious Exemption” in U.S. Copyright Law?
According to Section 110 (3) of the US Copyright Act performance of a nondramatic literary or musical work or of a dramatico-musical work of a religious nature, or display of a work, in the course of services at a place of worship or other religious assembly; a copyrighted musical or dramatico-musical work of a religious nature may be performed or displayed in the course or services at a place of religious worship or other religious assembly. This is an exception to the copyright owner's exclusive right to publicly perform the work. This exception does not extend to broadcasting (by radio or television), webcasting, live-streaming, podcasting, or recording of the parts of worship services that include copyrighted works, all of which require a license or the written permission of the copyright holder. This exception is for performance of the work, and does not permit publishing or projection of lyrics. This exception exclusively applies only during an actual worship service and does not include unrelated activities at a synagogue, camp, or other location that are not explicitly a religious worship service. You can obtain a license from JLicense to cover lyrics publication/projection, and rights for broadcast or live streaming.
→What are moral rights?
The Berne Convention explicitly recognizes a creator/author’s moral rights in a creative work. It recognizes as moral rights:
Paternity – the creator/author’s right to have their name on their work, to have their work properly attributed, the right to use a pseudonym, and the right to remain anonymous.
Integrity – The right of the creator/author to object to any changes to, modifications to, or uses of their work that they believe may harm their reputation as a creator/author.
Moral rights are not transferable and remain with the creator even if the work is sold or licensed to a publisher or other party.
The United States has taken a narrower view of the requirements in the Berne Convention in regards to moral rights, and does not enumerate those rights at the Federal level (except very narrowly for visual artists.) It should be noted that Israeli Copyright Law specifically enumerates an author’s moral rights, applying them to all creators/authors.
→Why is Copyright Law so strict?
Patent and Copyright law were of particular importance in the 1800s as the U.S. entered a period of major industrial growth and expansion. As inventors were given their due through patent laws, authors and creative artists started seeking protections as well. As noted in the section on the history of copyright in the U.S., prior to the creation of PROs in the 1900s, there was no mechanism
Speaking Jewishly, and as a not-for-profit religious institution, copyright infringement is not only illegal, but also a moral violation. Sales of products and licensing fees make it possible to pay our authors, composers, artists and songwriters, therefore encouraging them to produce new works in the future.
– Adrian Durlester (2017)