the public domain in books broke the dominance of the London booksellers and allowed for competition, with the number of London booksellers and publishers rising threefold from 111 to 308 between 1772 and 1802. Nevertheless, calls for perpetual copyright continued in Britain and France until the mid-19th century. Common law copyright After Donaldson v Beckett, disagreement continued over whether the House of Lords affirmed the existence of common law copyright before it was superseded by the Statute of Anne. The Lords had traditionally been hostile to the booksellers' monopoly and were aware of how the doctrine of common law copyright, promoted by the booksellers, was used to support their case for a perpetual copyright. The Lords clearly voted against perpetual copyright, and eventually an understanding was established whereby authors had a pre-existing common law copyright over their work, but that with the Statute of Anne parliament had limited these natural rights in order to strike a more appropriate balance between the interests of the author and the wider social good. According to Patterson and Livingston there remains confusion about the nature of copyright ever since. Copyright has come to be viewed both as a natural law right of the author and as the statutory grant of a limited monopoly. One theory holds that copyright's origin occurs at the creation of a work, the other that its origin exists only through the copyright statute. In 1834, the US Supreme Court ruled in Wheaton v. Peters, a case similar to the British Donaldson v Beckett of 1774, that although the author of an unpublished work had a common law right to control the first publication of that work, the author did not have a common law right to control reproduction following the first publication of the work. United Kingdom The Copyright Act of 1775 established a type of perpetual copyright which allowed "the Two Universities in England, the Four Universities in Scotland, and the several colleges of Eton, Westminster, and Winchester to hold in Perpetuity their Copy Right in Books given to or bequeathed to the said Universities and Colleges for the advancement of useful learning and other purposes of education." All provisions granting copyright in perpetuity were abolished by the Copyright, Designs and Patents Act 1988 but under transitional arrangements these rights do not fully expire until 2039. Separately, the Crown retains rights under the royal prerogative to control printing of