Proposition One Committee
PO Box 27217
Washington, DC 20038

September 8, 1999

SunSource
501 North Calvert Street
Baltimore, MD 21278
ATT. Robin L. Milligan
SunSource Inside Sales Manager

Dear Ms. Milligan,

This letter memorializes our telephone conversation of September 7, 1999, regarding your August 31, 1999 letter, i.e.,

"It has come to my attention that your organization has utilized the Baltimore Sun articles ('On this statue-fleck patch, homeless and protestors may rest their heads but not sleep,' by Robert Ruby and 'The Inauguration: A Grand Old Party,' by Susan Baer) and republished them on your web site (www.prop1.org).
"All permission for such republication is granted through the SunSource office. We have no record of your request for re-use or of a permission letter being issued for this material...."

As you know, it is my belief that our use of those two articles constitutes "fair use," pursuant to the provisions of 17 USC 107, i.e.,

Sec. 107. Limitations on exclusive rights: Fair use

Notwithstanding the provisions of sections 106 and 106A, the fair use of a copyrighted work, including such use by reproduction in copies or phonorecords or by any other means specified by that section, for purposes such as criticism, comment, news reporting, teaching (including multiple copies for classroom use), scholarship, or research, is not an infringement of copyright. In determining whether the use made of a work in any particular case is a fair use the factors to be considered shall include -
(1) the purpose and character of the use, including whether such use is of a commercial nature or is for nonprofit educational purposes;
(2) the nature of the copyrighted work;
(3) the amount and substantiality of the portion used in relation to the copyrighted work as a whole; and
(4) the effect of the use upon the potential market for or value of the copyrighted work. The fact that a work is unpublished shall not itself bar a finding of fair use if such finding is made upon consideration of all the above factors.

As you apparently agreed during our telephone conversation, (1) our web site is not of a commercial nature -- we do not make a penny off the site, in fact it costs us money to put it online, (2) the copyrighted work(s) depend entirely upon our vigil in Lafayette Park, and there would not have even been any "copyrighted work" if we hadn't provided the subject matter, (3) our web site is intended as a vehicle of criticism, comment, news reporting, teaching, scholarship, and research concerning the history of Lafayette Park, and the changing legal perimeters of freedom of expression in the nation's preeminent public forum; as such, the two articles to which you refer are merely footnotes to the substance of our web site, and finally (4) our use of these two articles has absolutely no effect "upon the potential market for or value of the copyrighted work."

As I also explained to you, because we do not solicit funds, nor do we profit from our web site, it is not possible for us to pay you the $200 per annum fee that you demand for use of these two footnotes.

In our conversation you were unable to supply any reason that our use of the contested articles was not "fair use" under 17 USC 107. I'm certain that you and your attorneys can find something more productive to do with your talents than to make an issue over whether our use of your footnotes is "fair use." Therefore, if you folks are absolutely set on going forth with this matter, I would request that your attorneys contact us with respect to legal precedents which support your position. If your attorneys can provide the legal grounds for contesting "fair use," we will be in a better position to resolve this matter while saving the time and expense of litigation.

Thank you for your prompt attention to this matter.

Sincerely,

William Thomas