 Similarly, estimates of lost sales translated to concepts such as lost jobs or reduction in individual or national incomes have been shown to be highly problematic.A 2009 court case, "United States v. Dove," ruled that the content industry equation of lost sales with illegal downloads is not valid, with the judge noting "Those who download movies and music for free would not necessarily purchase those movies and music at the full purchase price... although it is true that someone who copies a digital version of a sound recording has little incentive to purchase the recording through legitimate means, it does not necessarily follow that the downloader would have made a legitimate purchase if the recording had not been available for free.