reintroduced modified versions of them year on year. Printers, publishers and booksellers were concerned about the cost implications for original works, and for reprinting works that had fallen out of copyright. Many within Parliament argued that the bill failed to take into account the public interest, including Lord Macaulay, who succeeded in defeating one of Talfourd's bills in 1841. The Copyright Act 1842 passed, but "fell far short of Talfourd's dream of a uniform, consistent, codified law of copyright". It extended copyright to life plus seven years, and, as part of the codification clauses, repealed the Statute of Anne. Significance The Statute of Anne is traditionally seen as "a historic moment in the development of copyright", and the first statute in the world to provide for copyright. Craig Joyce and Lyman Ray Patterson, writing in the Emory Law Journal, call this a "too simple understanding [that] ignores the statute's source", arguing that it is at best a derivative of the Licensing Act. Even considering this, however, the Statute of Anne was "the watershed event in Anglo-American copyright history ... transforming what had been the publishers' private law copyright into a public law grant". Patterson, writing separately, does note the differences between the Licensing Act and the Statute of Anne; the question of censorship was, by 1710, out of the question, and in that regard the Statute is distinct, not providing for censorship. It also marked the first time that copyright had been vested primarily in the author, rather than the publisher, and also the first time that the injurious treatment of authors by publishers was recognised; regardless of what authors signed away, the second 14-year term of copyright would automatically return to them. Even in the 21st century, the Statute of Anne is "frequently invoked by modern judges and academics as embodying the utilitarian underpinnings of copyright law". In IceTV v Nine Network, for example, the High Court of Australia noted that the title of the Statute "echoed explicitly the emphasis on the practical or utilitarian importance that certain seventeenth-century philosophers attached to knowledge and its encouragement in the scheme of human progress". Despite "widely recognised flaws", the Act became a model copyright statute, both within the United Kingdom and internationally. Christophe Geiger notes that it is "a difficult, almost impossible task" to analyse the relationship between the Statute of Anne and early French copyright law, both because it is