Labels:book | reckoner | sky | tree OCR: element 17 even more critical than the quantity is the qualitative degree of copying: what degree of the essence of the original has been take. 'Rogers, 960 F.2d at 31. Thus in Harper Row copying only 300 tno of 200 ,000 words President Ford's memoirs was found militate against fair use because what wa taken was the "heart the book 471 11 565 66 568 Courts have recognized that in applying this third factor to parody some account must be taken of the parodist's need take enough conjure u the parodied Beriin Communtcations 329 F.2d 14 ln assure however that this qualification does not eliminate the third factor, courts have held that parody ust "take no more froni the original than necessary to accomplish reasonably its parodic purpose Fisfter Dees 794 .2d 439 We recognize that in some cases ...
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