Legal Stuff

‘Blurred Lines’ on Their Minds, Songwriters Create Nervously

15 April 2019

From The New York Times:

It’s not easy to be a songwriter in the pop world these days. Listeners rarely see your name. For anything but a giant hit, royalties from streaming are infinitesimal — and big tech companies seem to want to keep it that way.

And then there’s the shadow of “Blurred Lines.”

Four years after the copyright trial over that No. 1 song — in which Robin Thicke and Pharrell Williams, its primary writers, were ordered to pay more than $5 million for copying Marvin Gaye’s disco-era hit “Got to Give It Up” — the case still looms over the music industry and individual songwriters, who were left to wonder when homage bleeds into plagiarism.

Intellectual property lawyers and music executives interviewed for this article said the case had fueled a rise in copyright claims. In September, Ed Sheeran will go to court to defend “Thinking Out Loud,” a Grammy-winning song that has been accused of mimicking another Gaye classic, “Let’s Get It On.”

. . . .

The aftereffects of the “Blurred Lines” decision — which was upheld on appeal last year — have been felt most acutely by rank-and-file songwriters, who work in obscurity even as their creations propel others to stardom. The ramifications for them have been inescapable, affecting royalty splits, legal and insurance costs, and even how songs are composed.

The songwriter Evan Bogart, who has written for Beyoncé, Rihanna and Madonna, described second-guessing himself in the studio, worried that a melody or lyric might cross a line he can no longer locate.

“I shouldn’t be thinking about legal precedent when I am trying to write a chorus,” Mr. Bogart said.

Most accusations of plagiarism never go before a judge. Instead, they are settled quietly — and often protected with confidentiality agreements — with the results evident only in the fine print of writing credits.

. . . .

Occasionally, an outlying case will force industrywide adjustment. In 1976, for example, songwriters had to reckon with the idea of unintended infringement after George Harrison was found to have “subconsciously” based his first solo hit, “My Sweet Lord,” on a girl-group classic, the Chiffons’ “He’s So Fine.” After the decision, Mr. Harrison wrote in his memoir, he felt a “paranoia about songwriting that had started to build up in me.”

The “Blurred Lines” case, many lawyers and executives say, has become the latest watershed, putting the commonly understood rules of songwriting up for debate.

As songwriters often remark, there are only so many notes in the scale, and influence is essential to the art. Harvey Mason Jr., a songwriter and producer, said the “Blurred Lines” case “unnerved a lot of people writing songs, because a lot of what inspires creative people is the work that has been done before.”

. . . .

At the “Blurred Lines” trial, an eight-person jury heard detailed and esoteric testimony by expert witnesses from both sides about what, if anything, Mr. Thicke and Mr. Williams had copied from “Got to Give It Up.” The Gaye estate contended that specific musical passages had been lifted. Lawyers for Mr. Thicke and Mr. Williams countered that they had simply created a genre piece with a similar groove and feel, the kind of thing that musicians — and copyright lawyers — had long considered fair game.

In a dissenting opinion published when the case was upheld last year, Judge Jacqueline H. Nguyen of the United States Court of Appeals for the Ninth Circuit argued that the verdict allowed the Gaye estate “to accomplish what no one has done before: copyright a musical style.”

Mr. Thicke was also a fickle witness. He had given interviews citing “Got to Give It Up” as inspiration for his song, only to deny it in depositions, saying he had been intoxicated when talking with music journalists.

“I doubt if any more artists will tell Rolling Stone where they got their inspiration,” Tor Erik Hermansen, part of the songwriting and production duo Stargate, said in an interview.

Although the case did not result in any changes to copyright law, it has had a palpable effect. More songwriters are arming themselves with expensive insurance policies. And musicologists — academically trained experts who sometimes consult in copyright cases — are in greater demand.

. . . .

Songwriters now face heightened scrutiny of their work while it is still in progress, as record companies and music publishers sometimes vet new songs for echoes of past works.

“I’ve had a couple experiences where I was writing something and a lawyer and musicologist said, ‘It sounds like this old song, it’s a very active estate, they’re going to come after you,’” said Mr. Mason, who has worked with stars like Whitney Houston and Kelly Clarkson. “I changed a few notes.”

Link to the rest at The New York Times

Congress Shall Make No Law

6 April 2019

Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.

~ The First Amendment to The Constitution of the United States

Why More Artists Face Jail Around the World

6 April 2019

From The Financial Times:

The contemporary artist Luis Manuel Otero Alcântara was sitting peacefully on the steps of the El Capitolio building in Havana when the police came for him. Arrested ahead of a protest against a law that subjects all creative activity in Cuba to state approval, he cried out in pain as he was bundled into their car. I watched the shocking video footage in his apartment a few months later, in November last year. Two weeks later he was back in a cell along with his partner, curator Yanelys Nuñez Leyva, arrested on suspicion of planning another protest against Decree 349, as the law is officially known. Earlier this year I spoke to another redoubtable Cuban contemporary artist, Tania Bruguera, whose arrest in December was just her latest run-in with the authorities. In 2014-2015, she was detained repeatedly in the eight months after she tried to stage a performance, “Tatlin’s Whisper”, that asked citizens to speak freely into a microphone in Havana’s Revolution Square.

Her installation about the global refugee crisis graced the Turbine Hall of London’s Tate Modern this winter. “There is a moment when you understand you can lose everything,” she tells me at Tate when I ask about the strains of prison. “But my anger turns out to be bigger than my need for personal freedom.” These Cubans are part of a tide of artists enduring imprisonment around the world in recent years — a marked change from the 20th century, when writers were more at risk of persecution.

. . . .

Art and politics are old bedfellows. Yet on the whole, the Old Masters took care not to bite the hands that fed them. Paolo Uccello’s magnificent “Battle of San Romano”, a set of three paintings to commemorate Florence’s conflict with Siena in 1432, polished the military reputation of his city so brightly that two of the panels were stolen by Lorenzo de’ Medici from their rightful owners. Nearly four centuries later, Francisco Goya embarked on a series of etchings, “Disasters of War”, that revealed the horrors inflicted on civilians and soldiers during the 1808-14 conflict between France and Spain. He was described by his biographer Robert Hughes as one of the “true ancestors of war reporting” — though the etchings were never published during Goya’s lifetime.

. . . .

Increased politicisation is only part of the story. Ivor Stodolsky, who set up AR along with fellow curator Marita Muukkonen in 2013 to provide residencies for visual artists at risk of persecution in their homelands, suggests that the new threat to artists stems ultimately from the growing power of the media in which they work. “The 21st century is a visual culture,” he says. “It’s beginning to be our dominant form.”

Stodolsky believes that one of the reasons artists are in trouble is because “today, visual art is about more than just visuals”. Indeed, the art world is an increasingly cross-disciplinary landscape. Once the province of painting and sculpture, it now encompasses photography, film, sound and performance.

Link to the rest at The Financial Times

Here is one of Mr. Alcântara’s works

And a video by several Cuban artists.

.

B&N Press Now Offers Ebook Coupon Codes

30 March 2019

From The Digital Reader

B&N Press continues to add features, lending credence to rumors about an impending sale of the Nook division.

I just got an email from B&N, informing me that B&N Press now offered users ebook coupon codes and better formatting control over book descriptions.

Currently in beta, B&N’s ebook coupon codes give publishers the option to create a coupon code to market and sell their books at a specially discounted price to Nook readers. There’s no meed to worry about price matching on other retail sites., and users control all aspects of the campaign so that they can find and reward Nook readers. This feature is found in the Manage Promotions section from the Projects page.

Link to the rest at The Digital Reader

PG says he hadn’t thought about B&N Press for a long time.

His initial unmoderated response was similar to one he sometimes has when he sees an article about a movie star he remembers from his childhood – “Is she still alive?”

PG also wonders who might be interested in purchasing B&N Press.

The only entity that initially came to mind was Kobo, but, given Barnes & Noble’s general ineptitude in digital matters, PG suspects any potential purchaser would discount the price offered to take into consideration the expense involved in cleaning up the electronic back office.

Since Apple has a bazillion dollars stashed away and is looking at more content plays in general, perhaps it might buy B&N Press to beef up its offerings.

The first inquiry that comes to PG’s mind for either acquirer is how much overlap there might be between the titles published on Kobo, Apple Books and B&N Press. PG suspects most authors who don’t follow the path of ebook exclusivity with Amazon do so planning to go wide. Once you get your epub up on Kobo, is there a reason not to post it on Apple and B&N as well?

An additional factor that will keep the attorneys for any potential acquirer of B&N Press busy is a potential bankruptcy filing by Barnes & Noble in the future. Care must be taken to avoid having a B&N Press acquisition sucked into that morass.

Apple Violated Qualcomm Patent, U.S. Trade Judge Rules

26 March 2019

When it rains,

From The Wall Street Journal:

A U.S. trade judge recommended that some iPhones be barred from import on Tuesday after finding that Apple Inc. violated a patent held by Qualcomm Inc., handing the mobile-phone chip giant a victory in its long-running feud with its erstwhile business partner.

The decision from the U.S. International Trade Commission judge means that Apple, which has its iPhones assembled overseas before sending them to the U.S. and other markets, could be barred from selling iPhones that infringe on a Qualcomm patent covering strategies for conserving power and improving battery life. The judge’s two-page order didn’t specify which iPhone models it covered.

The decision by ITC administrative law judge MaryJoan McNamara, however, is subject to review by the full six-member ITC as well as by the Trump administration, either of which could change the findings and reverse the recommended ban. Presidents have vetoed ITC moves before, including in 2013 when the Obama administration prevented an ITC ban on the sale of some iPhones and iPads from taking effect after Samsung Electronics Co. won a case there.

. . . .

Qualcomm’s complaints against Apple—including another ITC case where a final decision was expected later Tuesday—are part of a world-spanning legal battle between the companies. The fight came to a boil in early 2017, when Apple sued Qualcomm in federal court in San Diego, alleging the chip maker extracted extortionate rates for patent licenses by leveraging its dominance in the modem-chip market. That case is set to go to trial next month.

The U.S. Federal Trade Commission also filed suit against Qualcomm in 2017, focusing on the chip company’s allegedly monopolistic practices. Qualcomm, which denies the claims and says its pricing practices are fair, has countered by alleging that Apple violated its patents in Germany, China, the U.S. and other jurisdictions.

. . . .

In a separate case brought by Qualcomm, a jury in San Diego this month found that Apple violated the same Qualcomm patent that the ITC found issue with in the case set for a decision later Tuesday. The jury awarded Qualcomm $31 million in damages for Apple’s violation of three patents in that case.

Link to the rest at The Wall Street Journal 

Our Software Is Biased like We Are. Can New Laws Change That?

24 March 2019

From The Wall Street Journal:

Lawyers for Eric Loomis stood before the Supreme Court of Wisconsin in April 2016, and argued that their client had experienced a uniquely 21st-century abridgment of his rights: Mr. Loomis had been discriminated against by a computer algorithm.

Three years prior, Mr. Loomis was found guilty of attempting to flee police and operating a vehicle without the owner’s consent. During sentencing, the judge consulted COMPAS (aka Correctional Offender Management Profiling for Alternative Sanctions), a popular software system from a company called Equivant. It considers factors including indications a person abuses drugs, whether or not they have family support, and age at first arrest, with the intent to determine how likely someone is to commit a crime again.

The sentencing guidelines didn’t require the judge to impose a prison sentence. But COMPAS said Mr. Loomis was likely to be a repeat offender, and the judge gave him six years.

An algorithm is just a set of instructions for how to accomplish a task. They range from simple computer programs, defined and implemented by humans, to far more complex artificial-intelligence systems, trained on terabytes of data. Either way, human bias is part of their programming. Facial recognition systems, for instance, are trained on millions of faces, but if those training databases aren’t sufficiently diverse, they are less accurate at identifying faces with skin colors they’ve seen less frequently. Experts fear that could lead to police forces disproportionately targeting innocent people who are already under suspicion solely by virtue of their appearance.

. . . .

No matter how much we know about the algorithms that control our lives, making them “fair” may be difficult or even impossible. Yet as biased as algorithms can be, at least they can be consistent. With humans, biases can vary widely from one person to the next.

As governments and businesses look to algorithms to increase consistency, save money or just manage complicated processes, our reliance on them is starting to worry politicians, activists and technology researchers. The aspects of society that computers are often used to facilitate have a history of abuse and bias: who gets the job, who benefits from government services, who is offered the best interest rates and, of course, who goes to jail.

“Some people talk about getting rid of bias from algorithms, but that’s not what we’d be doing even in an ideal state,” says Cathy O’Neil, a former Wall Street quant turned self-described algorithm auditor, who wrote the book “Weapons of Math Destruction.”

“There’s no such thing as a non-biased discriminating tool, determining who deserves this job, who deserves this treatment. The algorithm is inherently discriminating, so the question is what bias do you want it to have?” she adds.

. . . .

An increasingly common algorithm predicts whether parents will harm their children, basing the decision on whatever data is at hand. If a parent is low income and has used government mental-health services, that parent’s risk score goes up. But for another parent who can afford private health insurance, the data is simply unavailable. This creates an inherent (if unintended) bias against low-income parents, says Rashida Richardson, director of policy research at the nonprofit AI Now Institute, which provides feedback and relevant research to governments working on algorithmic transparency.

The irony is that, in adopting these modernized systems, communities are resurfacing debates from the past, when the biases and motivations of human decision makers were called into question. Ms. Richardson says panels that determine the bias of computers should include not only data scientists and technologists, but also legal experts familiar with the rich history of laws and cases dealing with identifying and remedying bias, as in employment and housing law.

Link to the rest at The Wall Street Journal

Should Government Criminalize Violent Artistic Expression?

17 March 2019

From Clannco:

Think of an artwork, song, film, video, poster, or photograph. In fact, with the omnipresence of social media, think of expression that any person—layperson or self-proclaimed artist—may disseminate into public space and which may be perceived as threatening to a group or individual. The creator of this expression may believe that her expression is just a “passive” and aesthetic expression of her thoughts and feelings and not an expression with intent to cause actual harm to a person or group. However, that person or group may believe, right or wrongly, that the expression constitutes a true threat against them. How then do we assess whether this threatening expression is in fact “true”?

In November 2013, a Pennsylvania trial court convicted a young, black rap artist, Jamal Knox, aka “Mayhem Mal,” for terroristic threats, witness intimidation, and conspiracy to commit terroristic threats. Knox appealed his conviction but the Pennsylvania Supreme Court affirmed the trial court. The conviction was based solely on the content of a song created in 2012 by Knox and Rashee Beasley, aka “Soldier Beaz,” that was uploaded to Facebook and Youtube. Knox’s song, “Fuck tha Police”—an obvious homage to NWA’s seminal 1988 release—contains lyrics about police generally as well as two Pittsburgh police officers who were involved in arresting Knox in 2012. The song lyrics expressed, in part, “I’ma jam this rusty knife all in his guts and chop his feet,” “artillery to shake the mother fucking’ streets,” and in relation to a police officer’s “shift over at three and I’m gonna fuck up where you sleep.” A Pittsburgh police officer who had been monitoring Knox and Beasley’s online presence discovered the song three days later, leading to the criminal charges against Knox and Beasley.

Can we objectively believe that Knox’s song constitutes a true threat? I don’t think so. In fact, Knox’s song presents us with a long standing tradition not only in rap but also other music genres (think heavy metal, punk, country) of including what some individuals deem to be violent and threatening lyrics.

. . . .

There is widespread disagreement among federal and state courts as to how to assess whether a statement is a “true threat” and thus unprotected by the First Amendment. Most courts apply what is called an objective standard, where the government is required to show that a reasonable person would regard the statement as a sincere threat. A minority of courts apply the subjective standard, which requires the government to show only the speaker’s intent to threaten. The U.S. Supreme Court had provided us with an answer to this question before, holding, in Watts v. United States (1969) that the First Amendment protects statements that a reasonable person would not regard as threatening. However, as often happens in Supreme Court jurisprudence, in a 2003 case, Virginia v. Black, concerning the constitutionality of a Virginia statute that criminalized the burning of a cross in public view “with the intent of intimidating any person,” the U.S. Supreme Court confused years of precedent by holding that true threats were “those statements where the speaker means to communicate a serious expression of an intent to commit an act of unlawful violence to a particular individual or group of individuals.” This confusion led some courts to read Black to mean that the standard now is purely subjective, and thus the government must show only the speaker’s subjective intent to threaten. Both Pennsylvania courts applied the “subjective” test in convicting Knox.

. . . .

Allowing the government to regulate expression that is in fact threatening to a person or group is reasonable. However, and as with any form of government action, this permission to regulate must be narrowly tailored. Allowing the government to convict and incarcerate individuals for expression that is not objectively threatening will restrain artistic speech and is contrary to First Amendment principles. In fact, the U.S. Supreme Court itself agreed, stating in Virginia v. Black that a ’hallmark’ of the constitutional right to free speech is “to allow ‘free trade in ideas’—even ideas that the overwhelming majority of people might find distasteful or discomforting.”

Link to the rest at Clannco

 

Seven Negotiation Lessons from Amazon’s Hq Disaster in Queens

16 March 2019

From Working Knowledge, The Harvard Business School:

As Amazon’s stunning pullout from New York fades into the news archives, its potent lessons for business negotiators risk being lost. Highly promising deals in diffuse multiparty settings with many potential spoilers, like Amazon’s planned headquarters in Queens, often collapse as a result of negotiating too narrowly with those who have formal power and authority. Negotiation experts have a patriarchal name for a version of this classic—and avoidable—mistake: Decide-Announce-Defend or DAD.

Along with gaining the full-throated support of New York Mayor Bill de Blasio and Governor Andrew Cuomo, Amazon officials understandably figured that the prize it offered New Yorkers would sell itself: 25,000+ jobs paying in excess of $100,000 each with all the ancillary economic benefits. Decide (on Long Island City, Queens), Announce (the choice), and Defend (from attacks) … and, if you’re still standing, you win.

Except, Amazon decided, announced, defended, lost, and abruptly pulled out, blindsiding virtually everyone involved. As New York’s chief negotiator for the deal mourned, this “was supposed to have been a coronation but instead was more like a coronary.”

. . . .

This surprisingly common result is why an “A” is often appended to DAD: “DADA” means Decide-Announce-Defend-Abandon. An apparently irresistible deal blessed by the top authorities runs aground on unanticipated opposition. The trail of such failed deals is long;

. . . .

For instance, consider the award of the 2024 Olympics to Boston over Los Angeles, San Francisco, and Washington DC. Boston’s successful bid was driven by the support of the state’s governor, Boston’s mayor, and many of its most influential citizens. Yet a small group of opponents catalyzed a local movement that, despite being outspent 1,500 to one by the bid’s boosters, ultimately caused the city to back out in 2015.

. . . .

The frequent failures of DAD-style negotiation have led some project advocates to seek consensus among all stakeholders. In a city like Queens, riven with many factions and political agendas, Amazon would never have reached full consensus and didn’t try. Requiring full consensus in a multiparty deal makes you hostage to the most extreme or reluctant party. When you can anticipate unconditional opponents, or skeptics with diverse agendas who may opportunistically band together, don’t hand them blocking power.

So let’s assume that, with many contenders, Amazon had powerful reasons to choose New York. Comparative advantages presumably ranged from a large and highly educated employee pool to big incentives and to local entertainment options galore—not to mention that, once Amazon’s new headquarters were built, much of New York’s congressional delegation could be counted on for political support . . . in addition to that from Washington State and elected officials from its other new headquarters in Virginia. Apart from avoiding the DAD and full consensus traps, what could Amazon have done to retain these New York advantages? What are the broader lessons for those facing similarly challenging negotiations?

. . . .

The goal should be to build “sufficient consensus” for a “winning coalition” in spite of potential blockers. This means earning enough support among enough of the right parties to gain agreement on your proposal and ensure successful implementation. Building such a sustainable winning coalition involves systematic steps that my colleague David Lax and I call a “negotiation campaign”.

  • In a complex, multiparty setting, don’t take victory for granted, ever. Today, social media can quickly amplify the views of even a few vocal opponents, giving voice to latent negative concerns of many otherwise passive groups. As Amazon learned, an apparent “movement” can seemingly spring up from nowhere. It can rapidly gain traction, surprising and thwarting the confident protagonists of an apparently popular project.

. . . .

  • Identify and nurture potential allies before you need them. To Amazon, the supporters seemed self-evident; after all, more than 200 cities desperately vied for the prize it bestowed on New York. Yet well-organized opponents overcame the unorganized supporters of the deal. Old-school reliance on the mayor and governor, powerful power brokers, proved unable to mobilize sufficient backing. Beyond cultivating elite support, a project sponsor should systematically work with community groups and local leaders so they feel intense personal and tangible stakes in the proposal. Detailed preliminary discussions with construction trades should make the huge amount of new work crystal clear. Early “job fairs” with sample applications could help persuade lower-skilled groups that thousands of new support jobs and training opportunities would be forthcoming along with the $100,000+ job bonanza for high-skilled workers. Community groups looking for improved parks, sidewalks, and local amenities could be nurtured at relatively low cost with “good neighbor” credible commitments. Failing to send CEO Jeff Bezos to New York to stroke the egos of local supportive politicians and learn firsthand of any qualms was a missed opportunity. Having identified and nurtured supporters, they can be activated in favor of your project if and as needed.

. . . .

  • Remember that negotiation does not end with a “yes,” but requires enough ongoing support for implementation and sustainability. The kind of negotiation campaign that I’ve sketched is designed to build a sufficient, sustainable “winning coalition” on behalf of an initiative like Amazon’s. But as this experience shows, an initial “yes” is only the entry point to a successful project, which requires sustained support for long-term success.

Link to the rest at Working Knowledge

At a recent lunch with a group of attorney friends, the discussion turned to negotiation successes and failures.

PG was reminded of an interest in Negotiations Studies from several years ago and did some online research to follow up with his lunch companions on a couple of discussion points.

Negotiation Studies is a serious field for academic research. The topic often overlaps both business and law schools since graduates of both will be involved in negotiations during their careers.

All business people, including authors, are likely to be involved in more than one business negotiation in connection with their work, so PG will drop a negotiation item into TPV from time to time. Publishing contracts immediately leap to mind. However, negotiated agreements with cover artists, editors and book designers are also possibilities for indie authors.

One of the basic ideas in Negotiation Studies is that a successful negotiation leads to a successful conclusion for both parties and, where applicable, a mutually-beneficial long-term business relationship. Seeking a win-win resolution is the optimum result for the large majority of business negotiations. The disastrous end of the Amazon/New York HQ2 negotiations results, as the OP indicates, at least in part, a failure to apply good negotiation practices and principles to putting the deal together.

One example of a poor negotiation outcome, at least in the United States, often involves negotiating the price and terms for buying a new or used automobile.

Shoppers worry about being subjected to high-pressure negotiation tactics, paying more than they should have paid for the vehicle, etc., etc. There are certainly enough short-sighted auto salespersons to provide some basis for that fear.

However, if the auto dealer or salesperson considers the lifetime value of a satisfied customer, it’s clear that being on the winning side of a zero-sum psychological manipulation sales session is not the best outcome.

One of the largest expense items for a great many businesses, including auto dealers, is attracting customers. Billboards, television commercials, radio ads, direct mail, the cost of an attractive dealership facility in a good location, etc., etc., are an enormous expenditure focused on having individuals who are interested in purchasing an automobile come to the dealership (and not go to a competing dealership).

If a customer has a positive car-buying experience, all sorts of additional benefits accrue to the dealership. When the time comes for the customer to purchase another automobile, are they more likely to return to a dealer (and individual salesperson) that provided them with a good acquisition experience than they are to take a chance on having a poor experience by patronizing an unknown dealer?

When it’s time to service their vehicle, is a satisfied customer more or less likely to bring the vehicle back to the dealership that treated them fairly (and, with a smart dealer, provides a positive service experience)?

If a friend or relative mentions they would like to buy a new car, is the satisfied customer more likely to recommend the dealer and salesperson who provided a good purchase experience and sold the vehicle at a fair price? Other than the purchase of a home, an automobile is likely to be the most expensive purchase a resident of the US (and perhaps other countries as well) will make during their lifetime. An auto dealer that makes the purchase process feel fair and easy is providing a service to the customer by reducing the anxiety that might otherwise accompany the expenditure of so much money.

Bringing the discussion back to authors and books, PG suggests the negative experiences that accompany some of the take-it-or-leave-it negotiation tactics many publishers employ do not redound to the publishers’ benefit over the long term. Effectively requiring that an author who feels competent to negotiate her/his own publishing contract to retain and pay for a literary agent is another poor business practice in the field.

Amazon, Draft2Digital, Smashwords, etc., are a delightful change for many authors who were previously published traditionally. Choosing their own editor and cover designer is another relief for authors who experienced revolving door editors and cover designs that were obviously created by the lowest bidder.

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