52. See Jessica Litman, The Exclusive Right to Read, 13 CARDOZO ARTS & ENT. L.J. 29, 40-42 (noting that under a view that "one reproduces a work every time one reads it into a computer's random access memory . . . any act of reading or viewing [a digital] work would require the use of a computer and would, under this interpretation, involve an actionable reproduction"); Pamela Samuelson, The Copyright Grab, WIRED Jan. 1996 at 137 (same); Pamela Samuelson, Legally Speaking: Intellectual Property Rights and the Global Information Economy, 39 Commun. Assoc. Comp. Machinery 23, 24 (1996) (browsing of digital works potentially infringing if "temporary copying that must occur in a computer's memory to enable users to read documents" is considered "reproduction" within meaning of Copyright Act); Post, supra note 45, at 103-04 ("If the very act of getting a document to your screen is considered the making of a copy' within the meaning of the Copyright Act, then a high proportion of the millions of messages traveling over the Internet each day potentially infringes on the right of some file creator . . . to control the making of copies. And, if the very act reading such documents on line involves copying, then some form of a license . . . would, in this view, be required for virtually every one of those message transmissions").