"People make films for different reasons. For money. Or, they make them because something in them demands artistic expression. I do it because I enjoy the work."

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Simply according artistic works the same protection as nonartistic works may not be sufficient to protect creativity. After all, the very essence of artistic expression is invention and artists necessarily draw on their own experience. But if the rules of liability are unclear, artists will not be able to know how much disguise is sufficient to protect their claims from the claims of those who may see themselves in the portrayals.

— Irving Kaufman