text:  See e.g. Heald, Paul J. “How Copyright Makes Books and Music Disappear (and How Secondary 
  16 
  Liability Rules Help Resurrect Old Songs).” Illinois Program in Law, Behavior and Social Science Paper 
  No. LBSS14-07 Illinois Public Law Research Paper No. 13-54 https://doi.org/10.2139/ssrn.2290181. 
  Accessed 4 Jan. 2020, at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2290181; Rosen, 
  Rebecca J. “Why Are so Few Books from the 20th Century Available as Ebooks?”*The Atlantic*, 18 Mar. 
  2014, www.theatlantic.com/business/archive/2014/03/why-are-so-few-books-from-the-20th-century- 
  available-as-ebooks/284486/. See also “Google Book Search Settlement and Access to Out of Print 
  Books.”*Google Public Policy Blog*, publicpolicy.googleblog.com/2009/06/google-book-search- 
  settlement-and.html. Accessed 20 Mar. 2024 (discussing this issue in the context of the failed class- 
  action settlement between Google, the Authors Guild, and the Association of American Publishers). 
  Google’s ﬁnal brief in the settlement proceedings notes the “prohibitive transaction costs of identifying 
  and locating individual Rightsholders of these largely older, out-of-print books” — see this brief at https:// 
  web.archive.org/web/20130112060651/http://thepublicindex.org/docs/amended_settlement/ 
  google_ﬁnal_approval_support.pdf. The Authors Guild and Association of American Publishers also 
  justiﬁed the settlement’s terms in light of the fact that “the transaction costs involved in ﬁnding 
  copyright owners and clearing the rights are too high”; while they argued that most works are not truly 
  “orphans,” they note that total transaction costs as a whole (including, for example, determining whether 
  the author or publisher holds the rights and then negotiating rates) are so high as to block uses of out- 
  of-print works anyway — see this brief at https://web.archive.org/web/20130112060213/http:// 
  thepublicindex.org/docs/amended_settlement/Supplemental_memorandum_of_law.pdf. 