advances in technology, including the handheld camera, as opposed to earlier studio cameras, which were much heavier and larger. In 1884, Eastman Kodak company introduced their Kodak Brownie, and it became a mass market camera by 1901, cheap enough for the general public. This allowed people and journalists to take candid snapshots in public places for the first time. Privacy was dealt with at the state level. For example, Pavesich v. New England Life Insurance Company (in 1905) was one of the first specific endorsements of the right to privacy as derived from natural law in US law. Judith Wagner DeCew stated, "Pavesich was the first case to recognize privacy as a right in tort law by invoking natural law, common law, and constitutional values." Samuel D. Warren and Louis D. Brandeis, partners in a new law firm, feared that this new small camera technology would be used by the "sensationalistic press." Seeing this becoming a likely challenge to individual privacy rights, they wrote the "pathbreaking" Harvard Law Review article in 1890, "The Right to Privacy". According to legal scholar Roscoe Pound, the article did "nothing less than add a chapter to our law", and in 1966 legal textbook author, Harry Kalven, hailed it as the "most influential law review article of all". In the Supreme Court case of Kyllo v. United States, 533 U.S. 27 (2001), the article was cited by a majority of justices, both those concurring and those dissenting. Brandeis and Warren article The development of the doctrine regarding the tort of "invasion of privacy" was largely spurred by the Warren and Brandeis article, "The Right to Privacy". In it, they explain why they wrote the article in its introduction: "Political, social, and economic changes entail the recognition of new rights, and the common law, in its eternal youth, grows to meet the demands of society". More specifically, they also shift their focus on newspapers: The press is overstepping in every direction the obvious bounds of propriety and of decency. Gossip is no longer the resource of the idle and of the vicious, but has become a trade, which is pursued with industry as well as effrontery. To satisfy a prurient taste the details of sexual relations are spread broadcast in the columns of the daily papers. ... The intensity and complexity of life, attendant upon advancing civilization, have rendered necessary some retreat from the world, and