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• In 1991, Basic Books and other publishers sued Kinko's Graphic Corp. for copyright infringement. Kinko's believed it was copying materials under fair use because the material was, in the end, used for educational purposes. In this case fair use was not proven.
• In 1992, the American Geophysical Union sued Texaco for copying and internally distributing copyrighted materials. The decision held that "companies in the for-profit sector that make copies of copyrighted journal articles violate fair use."
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