 And we'll also give the faculty member a chair. This is very special for me this evening because today we're recognizing Katherine Fisk becoming a Chancellor Professor of Law. Katherine is at a very distinguished academic career. She graduated from Princeton University, where she was summing up law. She then went to University of California Berkeley School of Law, where she graduated with a point of a coin. She then clerked for the United States Court of Appeals in the Ninth Circuit, Judge William Norris. Then she worked in Washington, DC, doing labor and employment law for the firm of Rogovan, UD, and Schollett. She then worked with the United States Department of Justice and the Civil Vision and Pellet Section. For those of your law students here, you'll also appreciate that her office made at the time was none other than a Gantt software. Katherine began her teaching career in 1991 at the University of Wisconsin. She also received an LLM degree from there. She then went, was on the faculty at Loyola Law School for many years, she was a professor of law. She joined the faculty at the University of Southern California as a professor of law, before then going to Duke Law School, where she also had an endowed share. She was the Douglas Maddox professor of law. She's written a number of books, her most recent book, Working Knowledge. It's one of two very prestigious prizes. It won the John Phillips Reed Prize. And it also won the Griswold Middleton Prize, both from Historical Associations. She's written many articles here at the Law School. She teaches legal profession and labor law, unlike when you teach an employment law and civil procedure for many years to come. It's only fitting that since this is a chancellor's chair, we're fortunate enough today to have the chancellor here to give it to her and say a few words. And it's a tremendous pleasure also to get you to introduce you to Michael Drake. For those of you who don't know the history of this law school, the simple reality is there would not be a law school at the University of California, Irvine, but it wasn't from Michael Drake. People who've been working in this community for years to create a law school, but it was only when Michael came here as chancellor that he was able to pull all the pieces together and get approval from the Regents of the University of California to have a law school. When it was his vision from the outset, it was to be a top 20 law school by every measure. I remember my very first conversation with him, my interviewer's office, who said, it's all about where you get on the track. That's where he has words, and he wanted us to be on the track at the top in the beginning. And he's made committed to that vision from the outset, providing the support and resources to make us a great law school from the outset. I can also tell you that he is a terrific classroom teacher, as Michael and I had co-taught a class for the last three years, most recently about three hours ago. Wonderful to see him interact with the undergraduates and see that in addition to being a terrific administrator, he's a wonderful being with the students. So let me turn it over to Michael, who will unveil the chair and say a few words. I thank you very much for the kind words, and I was very impressed with the accuracy and focus of your introduction on professionalism. So let me just say that it's great to see so many people here today, and so many who support the school, so many students, it's a great beginning. And the thing that we focused on from the very beginning were the people who were gonna come here and make it happen. And everyone knows that great universities are built around faculty, and attracting the very best faculty in the country to come and start this new adventure with us was our first order of business. And so we were so excited when we found that we were gonna be able to bring Catholic this to us. We have the chairs, Chancellor's chairs that we present to the most luminous faculty on campus, and the Law School is richly endowed with several Chancellor's Professors. I would also say that in addition to the work that Professor Fisk does in the Law School that she's taught undergraduates as well, and the dual or a double friend of being able to be a teacher in the professional world, but also to be involved in the broader university community is something that really makes this a special place. One of the things that we hoped to avoid in our Law School, which has been one of the characteristics of many other distinguished Law Schools is a separation between the Law School and the rest of the campus. The Law School of Catholic Attending, I know someone I know well who attended, didn't ever go much beyond the wall, would have been, I guess, the sort of northern wall of the Law School which would have been the southern wall of the campus, and for the three years that she lived there, and I had a son who was in Law School that never really got to the general campus as well, and so we, in the beginning, wanted to make sure that we had professors who were professors of law and something else, and the end would be a connection with the broader campus community because among our pillars, the pillars of one which we founded the school, and we wanted this to be an interdisciplinary enterprise that would raise a level of scholarship on the campus generally, and so we appreciate it so much when someone of Professor Fisk's broad experience teaches all the way unto undergraduate students to help bring them into this goal as well. So we're really, really pleased with that. I'll say finally that each of our professors has some particular area of specialty within the law, and I have to whisper this, I guess, but on a few occasions the campus finds itself wrestling with interesting issues that happen, they fall within the broad area of expertise of some of our special talent, and so I've had the privilege of being able to call captain late at night and say, what do you think about this? I don't know, forget what I call it. I do not provide legal advice. Yeah, I think about things that a neighbor could do. So it's been wonderful to have a colleague and a personal advisor, a professor for undergraduate students and a leader in the legal profession nationally join us, and so I'd like to say that we are now officially investing you in this particular position. There, did you see the chair get out of there? I mean, wait, look, why don't we just together? Oh, all right. One, two, three. Absolutely wonderful to be in a room with colleagues, friends, and students from many parts of my life. It really is such a special moment. The lecture that I'm about to give, which is some ideas for the book that I am starting to write, is a collaborative effort in the very best sense of the word. A lot of the people who make this work possible are in this room, including Diana Sahar, who gets me every book or anything that I ever ask for, students who've done research for me, people who've been sources of ideas and inspiration to numerous to count. So thank you all very much for coming to listen to what I have to say. Because I felt like this was such a weedy thing and because I was getting one of them, and this is not one of the libraries. Well, actually, this is the library's chair and because Tyce graciously let it out and the premise is just to show it off. And I'm so excited about actually having one of my own. But I wanted to actually sort of write a lecture so that I would be maximally articulate and be able to give to you some of the richness of some of my ideas, so here we have it. The legal regimes governing employment and intellectual property provide that firms own and control the intellectual property produced by their employees. As I explain in my book, employers in 1800 had almost no rights to employee generated IP. By 1930, the rules were diametrically the opposite. Corporations owned almost everything. Now we consider it unremarkable that corporations are, as a matter of law, the authors and inventors of many of the texts and technologies, the images and ideas that surround us. Yet we still imagine and experience the labor of creation as deeply human and individual, even when it is collaborative. Though corporations own the intellectual property and employee ideas, as employees, we still claim credit. Moreover, other employers and consumers still want to know who wrote that Super Bowl ad or who invented what parts of the iPod. Yet neither employment law nor intellectual property law speaks to this desire. Where creation is collaborative, but labor markets value individual creativity, the challenges in balancing individual and collective attribution are considerable and the stakes are high. Individual and collaborative creation demands attention even as corporate IP rights and employment contracts have occluded lawyers' view of them. Regardless of the dirt of what Roscoe Pound would call the law in the books, in workplaces, a set of social practices identified particular people with ideas. Although lawyers might not initially recognize these practices as law, a law in action does govern the allocation of credit for creating work. Today I will explore the law norms of attribution among Hollywood screenwriters and in a Madison Avenue advertising agency. These are two industries which value and attribute creativity, but which adopted contrasting practices about it. I will focus mainly on the 1940s and 1950s, a period when both industries were in transition away from being dominated by vertically integrated, pyramidally structured, and bureaucratically managed corporations. Men and women in both industries made a great deal of money writing. They were for companies which knew as one 1950s ad executive put it, that the company's most valuable assets wrote down the elevator every night. They were the knowledge economy before that concept passed from vogue to cliché. Writers in Hollywood, unlike writers on Madison Avenue, belonged to a labor union, and they were pretty militant unionists. Their union, the Writers' Guild of America, created the screen credit system. Film and TV writing thus is unique in American letters in having a worker-controlled process for deciding the meaning of authorship and for compensating workers based on the union's own credit determinations. In advertising, by contrast, there were no unions. There was also no formal system of attribution. Work was attributed to individuals, of course, in private for purposes that served the interests of the agencies and in the trade as a matter of the kind of common knowledge that defines community. My central argument today is that the contrast between Hollywood and Madison Avenue suggests that a strong system of employee collective representation leads to greater reliance on binding, transparent, and democratically created legal norms mediating creation, ownership, private attribution, and public recognition. By focusing on attribution and collective bargaining as crucial features of 20th century authorship, I have to confess I am swimming as the scholarly stream in both legal and literary studies. Scholars have tended to focus on the relationship between copyright law and an individual literary artistic model of creation associated with modernism in the arts and literature. This scholarly focus on authors and owners has been incondensurate with the relatively small percentage of 20th century creative people whose efforts were rewarded through copyright ownership. Once we realize that much modern creativity is exercised in an employment setting where salaried creators sign away their rights and their work as a condition of hire, sign away, in effect, their very status as authors, we can see that attribution of work rather than ownership of the intellectual property represented in it defines the modern connection between creators and their work. I hope to dispel the impression that ownership is authorship by showing that copyright is not the only place. Perhaps with all due respect to my beloved colleague Tony Rees, not even the most important place to study the role of law in shaping the nature of creative work in the modern period. Modern authorship, I argue, is only partly defined by soul creation and individual rights and incentives, just as significantly, authorship is constituted by social and legal processes of recognition, processes that pertain to both individuals and firms. Before delving into the details about Hollywood and Madison Avenue, let me suggest five ways in which attribution of work matters to workers and to employers. Attribution rewards creators and thus provides a motivation for innovation. In many instances, there is intellectual property ownership as one of the principal psychic and economic rewards of innovation. Second, attribution disciplines creators by providing a mechanism to connect shoddy or undesirable work to individual people. Third, attribution brands, products which enhances their value. Particularly in the case of mass produced consumer goods, attribution gives a social meaning to everyday objects, as in the designer label on clothes. Attribution mediates the relationship between vast corporations and consumers, serving as a mark of authenticity in a world in which commercialization of culture makes everything or threatens to make it uh-huh, phony. Attribution in the form of a byline of a respectable journalist at a respectable news source, and propaganda in mass political culture. Fourth, attribution creates human capital by linking people to their work product and thus evidencing their knowledge and ability. And fifth, attribution humanizes work, linking consumers to real people who would otherwise be anonymous inputs into production. In all five of these aspects, attribution has a value distinct from the value of intellectual property or human capital to which it is attached. The commodity value of attribution is entirely informational. It tells consumers, current and prospective employers, creators, and the world at large about products and their creators. The commodity value of attribution is dissipated if the right to it is transferred because the information that it conveys is lost. Hence, whether attribution customs are formalized, as you will see they are in Hollywood, or remain informal as in the case of advertising, there is a limit to the tolerance for inaccuracies. Come with me now to consider the law and norms of attribution in two central institutions of modern culture in the 1940s and 50s. First, Madison Avenue and then the Hollywood Riders Guild. In 1957, Howard Cole, who was a senior executive of the J. Walter Thompson Company, which was then the largest advertising agency in the United States, sent a memo to members of the New York office of the firm. The memo was part of a decades-long series of company efforts to bring professionalism and efficiency to the management of the creativity involved in advertising. J. Walter Thompson, or JWT as the firm had come to be known and is still known, prided itself on having modernized the business of advertising during the 1920s and 30s. All agencies pride themselves on having invented modern communication, but JWT particularly prides itself on having invented the modern management of the conditions of production of modern communication. I kid you not. JWT, an account representative was in charge of relations with the client and coordinating the work of the writers, artists, to design and advertisement. And if you watch Mad Men, which is the only TV show I do watch, he sort of glues all of that, but that's really the drama in the show. Cole's memo warned that the tendency of these account representatives, quote, to use creative people and specialists in daily and regular contact work with our clients, does not serve the best interest of the client and can be dangerous to the well-being of the company. He said it would undermine the company's ability to present clients with, quote, our completely objective viewpoint. The representative, he said, should be a buffer between the client and the agency. In addition, he continued, the fine work of a creative man or a specialist can, on occasion, be rendered ineffective or unusable because of personality problems. That's Interoffice Memo's story. He said, that's Interoffice Memo's speak. Moreover, contact with clients, he said, could reduce both, quote, the time creative people and specialists have available for actually producing and working on the problem and the number of problems creative people and specialists could work on, which would, in turn, opiate their ability to bring a broad experience and the invaluable stimulation that comes from working on a variety of problems. In other words, he wanted them to specialize. And this is really important. He said, the account representative, would, quote, reduce his value to that of a messenger boy if he places on others the major responsibility in presenting the agency's work. As this memo illustrates, JWT executives insisted that the key to success in the world of advertising was the wise management of creativity by assimilating the manufacturer of ideas, texts, images and sounds into the dominant system for manufacturing and manufacturing cars. Cole's memo embraced three aspects of mid-20th century management theory. First, to be a professional, even in the world of writing and design, was to remove the idiosyncrasies of personality and individual point of view from the work process and product. Second, efficient workplace management demanded a sharp division of labor between creativity and management. And third, the success of the firm depended upon managers maintaining control of creative workers. Cole's memo exerted just this type of managerial control even in the course of describing it. Now, while Howard Cole was urging the creative people to be kept away from client meetings, other JWT executives were advocating just the opposite. They feared that bureaucratic management of the creative process was alienating creative labor. One sided a writer's complaint that he had been reduced to working while others had complained about feeling lost in a large firm where they turned out ideas, artwork, or text and stuck them in the outbox on their desks each day. Worried that bureaucratic employment practices could not easily be reconciled with individual creativity, one executive proposed that especially talented staff were deserving of greater publicity while another proposed that the public recognition of creative staff could reduce alienation and improve the company's reputation for creativity. Bill Day, a JWT executive who eventually left to form his own agency which I think quite famous, urged the firm, quote, to stress individual progress, individual cultivation of individual talents very much more than we have been stressing them. According to his view, creative work could not be assimilated into the managerial model of manufacturing. At JWT as it turned out, the anonymity model carried the day. Although those in the industry know which agency has which count and which agency is responsible for which major campaign and creative directors receive awards for the work of their team at annual awards banquets that look a lot like the Academy Awards actually, the public generally does not know who produced which ad. It is a labor market that operates on an entirely informal set of attribution norms. The agency executives cared a great deal about who did which ad and they were constantly looking out for new talent. But the process by which ads were attributed to people and by which talent was assessed based on attribution remained informal and very much in the control of managers. Like other ad agencies, JWT competed for clients on the reputation of its human capital. They promoted the firm as having transformed advertising from 19th century to a modern profession through the particular talent of the staff in applying science to marketing and modernism to art and design. The modernization and professionalization of advertising as they saw it primarily entailed hiring Yale graduates as writers and university professors to conduct market research and then managed them as if they were factory workers. For all the talk about modernization JWT was quite relaxed at least by today's standards and the agency did not even claim ownership of the firm. In the days when the agency wrote and produced radio programs for its clients to sponsor the show's writer might own the script even though he or she was technically a JWT employee. Those of our students who are refugees from Hollywood would recognize how unusual the firm was. The agency did not use written contracts for its employees. It relied on corporate culture and Hollywood would recognize how unusual that would be today. Composers of music for radio programs sometimes retained the rights to the music and JWT licensed the songs under the ASCAP system just as a broadcaster would have. In some of the shows it produced for clients and sponsors in the early days of TV JWT hired writers without a written contract and simply assumed that it owned the scripts as works made for hire. Just as the agency did not uniformly insist on the property side of authorship it was inconsistent about attribution. Generally the company leaders preferred anonymity. One executive said about Stanley Resor who was the company's long-time head that he would quote, never let anyone have credit for even an ad. It was a company job. The whole thing was company, not one person. Similarly Walter Lord who was a copywriter for the firm before he published I don't remember in 1955 who was a popular book said the Thompson Company deliberately clouded the matter as to who was responsible for a particular ad. Mr. Resor believed so firmly in the team idea that an individual was never known as the person who wrote such and such an ad. Keep yourself out if you want to get your idea across as the cardinal rule. There was supposed to be no hierarchy just collective achievement through individual creative effort and spirited collaboration. That's why we depreciated titles. We didn't have labels or titles. We didn't sign our names individually to projects. We signed our work J.W. Thompson. The contrast between the company's general policy of non-attribution and the culture of attribution that had emerged in radio, film and television became apparent when J.W.T. produced radio and TV programs for its clients. As one executive later recalled as you look back at the credits for writing, directing and producing these and other J.W.T. shows another striking thing stands out. The credits look like a roster of J.W.T. radio department talent. In those days J.W.T. wrote all the material their stars used on the air. The stars might be getting $5,000 to $7,500 a week and the writers and directors might be getting that much a year but no credits on the air or in the trades. Ours was an anonymous society and our only accolade after a particularly fine show, one which wrote New Ground, was an Orchid which we would find on our desks the morning after from J.W.T. Vice President John Reaver. Privately and within the world of ad agencies, J.W.T. did attribute work both to itself as a firm in the case of ads that were nominated for awards and to individual employees. Attribution however to the strategy of bureaucratic rationality. The business of managing creative talented required processes for spotting and nurturing talent which in turn required tracking the work of individuals. dossiers of employees accomplishments were used for example to set their salaries as one memo put it as nearly as possible in proportion to individual contributions. These same dossiers were used to match the talents of individual employees to the demands of particular clients and campaigns. Other mid-20th century tenets of bureaucratic management insisted that the organization had to present a human face to its employees. The company Newsletter which was published weekly or bi-weekly for decades in which I confessed to have read every single issue of routinely profiled individual employees and often attributed slogans, ideas or other aspects of ad campaigns to them. In addition to background and development and particularly successful campaigns was recounted in the newsletter like the successful Uncola campaign for 7 Up in the early 1970s or the this is a funny one she's lovely, she's engaged she uses POMS campaign of the 1940s which was actually created by the women's department at JDFJ they had a whole separate women's department which the women insisted on with their good ideas and they were credited with being far more effective than the men at bringing sex appeal into advertising. Company lore sometimes lionized the past accomplishments of particular company leaders as a way of dignifying the firm and inspiring younger employees but it was all ad hoc and discretionary with upper management. Come with me now across the country to Hollywood. Creativity is valued just as much, compensation and prestige are just as great as agency, job security is just as scarce and work is equally collaborative. Even screenwriting the most solitary and individualist of the some of the more high-profile contributions to emotion picture is collaborative yet in contrast to advertising authorship of films is very publicly attributed. In Hollywood writers belong to a union and that has made all the difference. In 1942 after two decades of struggle screenwriters finally secured their first collective bargaining agreement with the studios. That minimum basic agreement as it is called stated as the current one still states quote credits for screen authorship shall be given only pursuant to the terms of and in the manner prescribed in the contract and in the screen credits manual which is drafted by the writer's guild and adopted by a vote of guild members. Credit determinations are both thoroughly and substantively complex. They consume a significant amount of the time of the guild's professional staff. In addition the union has elaborate processes for studying and evaluating its credit rules. Standing committees of members debate the rules, member preferences are polled, meetings of the entire membership are called to debate the proposed changes and all members vote. Although individual hiring contracts for writers supplement the basic agreement on scores of issues and tend to be quite lengthy and detailed, on screen credit they are very short. Credit will be determined according to the collective agreement. Credit and forms of compensation tied to it that is separated rights and residuals which are complicated but they're sometimes quite valuable, are the one area for which writers cannot negotiate individual deals. Even hiring contracts for writers on projects not covered by the union agreement often stipulate credits per the writer's skill. Writers work very hard to achieve this state of dominance in determining writing credits. The credit determination process has changed relatively little all things considered since the union took it over from the studios in 1942. When the film is in post-production the studio makes a tentative determination of writing credits and sends notice of its determination to the guild and to all writers involved in writing the film. If no writer objects the credits are as determined by the studio. If any participating writer objects the guild arbitrates. The arbitration consists of three guild member writers reading all the literary materials whatever the original material was and every version of the script including the final shooting script and determining which writers made the most significant contributions to the film. In evaluating the significance of contribution arbitration committees consider four aspects of a script plot, characters, scenes, and dialogue and then they write up a little opinion each individually and send it back to the guild. Writer control of the credits has been encountered a serious threat from 1947 until about 1960 during the era when studios blacklisted suspected communists. Blacklist operated in significant part through the denial of screen credit. The studio simply began to refuse to accord credit to any writer who was suspected of being a communist. Some blacklisted writers as we now know continue to be hired but they wrote under false or borrowed names or indeed under no name at all. The 1957 film Friendly Persuasion which won the Palme d'Or Actan and was nominated for a Best Screenplay Academy Award was credited to no writer because the studio believed the writer was a communist. After a series of anguished membership meetings intensifying among union members and unsuccessful court challenges in which the writer's guild actually hired Thurman Arnold the writer's guild eventually acquiesced in the studio's blacklist and agreed to a modification of the collective agreement that allowed the studio to deny screen credit to some writers. And this is the interesting part I discovered while I was digging through the files. While conceding the power of the producers to deny credit to communists and those who refused to testify about it, the guild insisted on its continuing power to control credits. It considered the orderly operation of its credit process so important that it conducted credit arbitration at the request of blacklisted writers whom the guild knew would never be given credit by the studios. The guild conducted a credit arbitration whenever a writer who had been employed on a picture challenged the denial of credit and it made no exception for blacklisted writers. Of course because the arbitration process is now and always was anonymous the arbiters did not know they might be deciding to award credit to a blacklisted writer. When the arbiters finished the guild's longtime credits administrator would simply translate the arbitrator's decision which is written as writer A should receive whichever kind of credit screenplay by credit for example into the usual form letter that the guild was always used stating in a few sentences that the arbitration committee had decided whom should be given what form of writing credit and the studios ignored the guild's determination when the writer was a communist as the guild knew that the studio would but the wheels of the guild's credit determination process cranked on. The stack of the credit arbitration machinery continued even when it was futile is what paved the way for the guild to regain power over credits when the blacklist began to fall apart around 1960. To make a long story short when a few producers began to buck the practice of denying credit to writers the guild's ongoing process for determining screen credit was right there as it had been all along. The long books once more became the law in action. Before during and after the blacklist period the union's reliance on law is no accident. Legal processes and legal rules enable the union to make difficult and extremely high stakes choices about which of its members will get the considerable financial rewards of credit in an environment in which all participants know that authorship is collective but credit determinations are individual and are limited and always have been limited to two people a maximum of two or two teams of two absent waiver. A democratic process for adopting the rules and a regularized process for applying them protect the union as an institution as well as the writers as individuals and the very limited judicial review of guild's administration of the system reinforces the guild's tendency toward legalism in administering credit under the labor law duty of fair representation which is a legal doctrine. The guild's determination is final and the guild will not be subject to damages for making errors in attributing films so long as its determinations are not arbitrary discriminatory and in bad faith and the guild has won every single lawsuit in which a writer who was denied credit has alleged that the decision was arbitrary discriminatory or in bad faith. This is a substantial financial incentive for the guild to use a process with all the trappings of the rule of law. The guild's management of credit enables it to play a unique and little understood role as a labor market intermediary. First it facilitates the assessment of talent in a fascinating market in which people switch jobs all the time and production companies spring up and disappear for each movie or a couple of movies. Credit on a project enables the writer who is once hired to get hired again. In addition residuals which is a form of profit sharing that turns on screen credits not a share of copyright royalties it's actually a different form of profit sharing. Compensates writers during periods of slack employment thus keeping their human capital in the industry once they achieve a certain level of success. These two functions of credit along with a bunch of other things that I have time to explain here may explain why the writer's guild survives even though there is a huge surplus of labor in Hollywood that might be willing to work non-union and why disgruntled writers do not join forces with producers to break the union and drive down labor costs which as we know has happened in so many other areas of American industry. Through control of screen credit and the compensation that turns on it the writer's guild has created a system of private intellectual property rights that is in my view as important as copyright to the operation of both labor and product markets in Hollywood. It is a unique system of private ordering that underlies a multi-billion dollar industry and it is a system that has operated for decades with virtually no judicial or legislative intervention. Having given you a brief description of attribution norms and processes in these two industries let me now share with you some of my ideas about the challenges and rewards of this work and I promise I'm almost done. When I first began working on this I thought my principal problem was that I wanted to write a legal history about something that was not law. I had surveyed attribution practices in a number of industries including speech writing, journalism, law, engineering and software development and I was troubled that such an important issue for employees and for firms seemed to be handled without any obvious deliberation and without transparency and without any law. I first turned to Hollywood because I was concerned that as a legal scholar I better go find myself some law to study and it was helped that the writer's guild dig around in their files for weeks. But now I think the principal problem of the project may also be its principal virtue. It is a unique opportunity to make intelligible a set of practices in which law is made that is quite distinct from our usual understanding about the making of law. Of course the problem is many of the recognized scholarly practices of legal historians don't fit what I'm going to do. This is not a project in which I'm telling the story of a legal institution like judicial review or a core doctrinal category like contributory negligence nor is it really an intellectual history of a legal concept situating it in social, religious, political or economic thought. It is not to show how law played some significant role in shaping society such as how early 19th century tort law facilitated capitalism or to show the social causes of legal phenomena such as the impact of the 19th century capitalism on the rise of the limited liability corporation. It is not even like the work of so many eminent social, cultural or legal historians that use legal sources to uncover phenomena that haven't been thought of as legal, such as the way in which legal processes came to define the meaning of race. It is rather a study of non-legal sources to uncover a phenomenon that hasn't been, but should be thought of as legal. Other historians and social scientists have, of course, found law in the tapestry of the customs of community. I'm not the first person to try this. This has been done for mining rights in Gold Rush, California and Bob Ellison's famous work on cattle ranchers and his more recent work on the household and in studies of the practices of 19th century whalers competing over a single whale. What is unique about we will write about that. It's actually really interesting. What is unique about this project is the contrast between the set of attribution practices that developed in a top-down organization like an ad agency and those that employees developed for themselves through their union. The fact that Hollywood writers were unionized and had lawyers meant they built a democratic system with a fair amount of process. So let me conclude. I don't think there is anything inherent in the distinction between movies on the one hand and advertising on the other that meant that one necessarily was going to be signed and credited and the other would not be. Ads could have had signatures in the way that paintings, photographs, or newspaper articles do. And indeed, many recognized artists worked for ad agencies. Edward Steichen, a famous 20th century photographer, worked for J.L.U.T. for a period of time and he signed his work when it was in a gallery and not when it was in an ad. Movies could be credited just to companies or just to directors or producers which is what the directors and producers do if they can go away with it. The authory attributions in motion pictures and TV are, in my view, a result of the power that writers had in Hollywood and the fact that production companies came to see writer control and writer credit as beneficial to them. The power of writers and the institutional capacity to translate their intuition about the importance of attribution into a system of law did not come just from Hollywood writer's education or talent. For Madison Avenue writers had plenty of both because he was fundamentally the same kind of people doing this work in this period. It came from their union. We hear lots of talk today about private systems of rules and norms that constrain conduct such as codes of conduct governing corporate ethics or environmental protection or the internet or international labor standards. It is important to remember I think as we evaluate these private and soft law systems that it takes sturdy and democratic institutions to translate high minded ideals into meaningful constraints on opportunistic behavior. In Hollywood at least a union did that. And that might be something to remember as we contemplate what role privatized regimes of rules can play now and in the future. Thank you.