Fox routinely took Wood images and made cards of them. Until Napoleon Sarony sued over copyright infringement and won [Burrow-Giles Lithographic Co. v. Sarony, 111 U.S. 53 (1884); Supreme Court upheld the power of Congress to extend copyright protection to photography], it was not clear that photographers could enforce their copyrights. A few years later apparently it was still lucrative for pirates to steal images and make cards.
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