early 1896. When Hearst predictably hired Outcault away, Pulitzer asked artist George Luks to continue the strip with his characters, giving the city two Yellow Kids. The use of "yellow journalism" as a synonym for over-the-top sensationalism in the U.S. apparently started with more serious newspapers commenting on the excesses of "the Yellow Kid papers". In 1890, Samuel Warren and Louis Brandeis published "The Right to Privacy", considered the most influential of all law review articles, as a critical response to sensational forms of journalism, which they saw as an unprecedented threat to individual privacy. The article is widely considered to have led to the recognition of new common law privacy rights of action. Spanish–American War Pulitzer and Hearst are often adduced as a primary cause of the United States' entry into the Spanish–American War due to sensationalist stories or exaggerations of the terrible conditions in Cuba. However, the majority of Americans did not live in New York City, and the decision-makers who did live there probably relied more on staid newspapers like the Times, The Sun, or the Post. James Creelman wrote an anecdote in his memoir that artist Frederic Remington telegrammed Hearst to tell him all was quiet in Cuba and "There will be no war." Creelman claimed Hearst responded "Please remain. You furnish the pictures and I'll furnish the war." Hearst denied the veracity of the story, and no one has found any evidence of the telegrams existing. Historian Emily Erickson states: Hearst became a war hawk after a rebellion broke out in Cuba in 1895. Stories of Cuban virtue and Spanish brutality soon dominated his front page. While the accounts were of dubious accuracy, the newspaper readers of the 19th century did not expect, or necessarily want, his stories to be pure nonfiction. Historian Michael Robertson has said that "Newspaper reporters and readers of the 1890s were much less concerned with distinguishing among fact-based reporting, opinion and literature." Pulitzer, though lacking Hearst's resources, kept the story on his front page. The yellow press covered the revolution extensively and often inaccurately, but conditions on Cuba were horrific enough. The island was in a terrible economic depression, and Spanish general Valeriano Weyler, sent to crush the rebellion, herded Cuban peasants into concentration camps, leading hundreds of Cubans to their deaths. Having clamored for a fight for two years, Hearst took credit for the conflict when it came: A