Authors – time to lawyer up?

The United States Supreme Court has refused to hear an appeal of a lower court’s ruling that digital music royalties should be treated as a license.  Given the similarities between music and book contracts, the implications for authors are significant. Below is our original article on the subject published in October 2010.

Don’t just stand there. Look at the royalty language in your book contract.

RC

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Is there a reason why publishers are not wailing, gnashing their teeth and rending their garments over the Eminem decision?

Maybe they haven’t heard about it. Maybe they don’t understand it. Maybe they don’t think it applies to them. Maybe they just don’t want to think about it at all.

They really must think about it and so must you. The case heard by the Ninth Circuit Court of Appeals was ostensibly about music but you can bet it won’t be long before it’s about e-books, and it could throw the publishing industry’s royalty structure into chaos.

Ethan Smith of the Wall Street Journal explains the issues (the italics are ours): “Under most recording contracts, artists are entitled to 50% of revenue from licensed uses of their music. That usually means soundtracks for movies, TV shows and ads. Sales, on the other hand generate royalties for the artist at a much lower rate—generally in the low teens, and rarely more than 20%.”

For “recording contracts” read “publishing contracts”. Under current book industry standards publishers pay authors a 25% royalty for e-book sales. Their contracts also call for a 50% share of e-book licenses made with third parties. But publishers do not consider e-book revenue to be license revenue. If they did they’d have to pay authors 50% of what they receive rather than half of that amount.

In the case in question, Eminem’s producers F.B.T. Productions brought a lawsuit against Aftermath Records claiming that what Aftermath defined as sales were really license revenues and Aftermath therefore owed them the difference between the low royalty they were being paid and the much higher share of license money. The three judge panel of the San Francisco Federal court agreed:

Pursuant to its agreements with Apple and other third parties…, Aftermath did not “sell” anything to the download distributors. The download distributors did not obtain title to the digital files. The ownership of those files remained with Aftermath, Aftermath reserved the right to regain possession of the files at any time, and Aftermath obtained recurring benefits in the form of payments based on the volume of downloads . . . Under our case law interpreting and applying the Copyright Act, too, it is well settled that where a copyright owner transfers a copy of copyrighted material, retains title, limits the uses to which the material may be put, and is compensated periodically based on the transferee’s exploitation of the material, the transaction is a license.

For a cogent analysis of the case and its implications for the book industry, read Copyright Alert: 9th Circuit Holds Digital Downloads are Licenses Not Sales by copyright authority Lloyd J. Jassin, to whom we’re indebted for bringing the case to our attention.

It will not surprise us to find a flurry of amendment letters from publishers in the next few months saying “Wherever we refer to ‘royalty’ we mean ‘license’ but we’re still going to pay you 25% of what we receive.”

Richard Curtis

One of the most commonly asked questions authors pose when they read their first book contract is, “What are special sales?”

The simple answer is that they are sales outside of “regular trade channels” – that is, bookstores. An example might be a fly-fishing book sold in an outdoor clothing store or a baby-naming book sold near the checkout counter of a maternity shop.

The phrase is buried in a tedious list of royalty rates applicable to marginal retail outlets.The royalty is expressed as a function of the publisher’s net receipts – as opposed to the list-price royalty paid by most trade publishers for bookstore sales. A net royalty always tells you that the cost of generating sales is higher than that for regular trade channels.  In the case of special sales, those gift shops and stationery and maternity stores insist that the books they order from the publisher are not returnable.  That means that publisher must slash its discount, leaving little by way of profit margin.

Until recently special sales were a throwaway line on the royalty schedule of a book contract. Not anymore.  Like every other phrase in a publisher’s boilerplate, some exciting new book marketing is sending contract managers back to that phrase in order to make sure they exact full value from the phenomenon.

What has inspired this sudden surge of interest?

“Kitson, a group of boutiques based in Los Angeles, is the kind of store that appears regularly in the tabloids for both its stylish clothes and its celebrity clientele like Sean Combs and Joe Jonas,” write Stephanie Clifford and Julie Bosman in the New York Times. “But in a town that is all about flash, Kitson is finding a surprising source of revenue that is not from its fashionable shoes or accessories. It is from books. The company’s owner, Fraser Ross, estimates that Kitson sold 100,000 books in 2010, double what it had the previous year.”

The phenomenon is by no means a west coast fad.  “A wide range of stores better known for their apparel, food and fishing reels have been adding books. The fashion designer Marc Jacobs opened Bookmarc in Manhattan in the fall. Anthropologie has increased the number of titles it carries to 125, up from 25 in 2003. Coldwater Creek, Lowe’s, Bass Pro Shops and even Cracker Barrel are adding new books.”

Non-bookstore retailers love books because they seldom have to reduce the price to get rid of them. The affluent clientele that that patronizes these shops is not looking for markdowns on books.  And books lend tone to the other merchandise. “They can drive other purchases and help with branding,” the Times writers explain in Publishers Look Beyond Bookstores.

Richard Curtis

Every Blogger owes a debt of gratitude to newspapers and magazines. This posting relies on original research and reporting performed by the New York Times.

HarperCollins authors – have you read your Ten Commandments lately? How about the Seven Deadly Sins? You’d better bone up on them. It seems there’s a morals clause in your publisher’s contract. Not moral rights, mind you (for a discussion of Droit Moral click here). We mean morals. Your morals.

New language in the termination provision of the Harper’s boilerplate gives them the right to cancel a contract if “Author’s conduct evidences a lack of due regard for public conventions and morals, or if Author commits a crime or any other act that will tend to bring Author into serious contempt, and such behavior would materially damage the Work’s reputation or sales.” The consequences? Harper can terminate your book deal. Not only that, you’ll have to repay your advance. Harper may also avail itself of “other legal remedies” against you.

We learned about Harper’s morals clause in an article by Brooklyn attorney F. Robert Stein published in the November 2010 issue of the Novelists Ink Bulletin and brought to our attention by author and editor Steve Carper. (The complete text of the provision can be found at the end of this posting.)

Does this mean that if you covet your neighbor’s wife, Harper could cancel your contract? Probably not, though you should try to modify the clause to prevent arbitrary application of the provision.

Where the morals clause is more likely to come into play is when your sin damages Harper’s ability to sell your book. Stein puts it this way: “I strongly suspect that HarperCollins could care less about their authors’ morals…unless and until a moral indiscretion threatens to reduce the value of the author’s book. Imagine if former New York Governor Eliot Spitzer had, during his term in office, contracted with HarperCollins to write a book entitled I Choose to Be Purer Than Caesar’s Wife.  Once Spitzer’s dalliances with multiple prostitutes became public, the potential audience for that book would likely have dropped precipitously, and HarperCollins’ ability to recoup its advance would have been seriously compromised.”

We are not aware of any other major publisher with a morals clause, and though we can appreciate why Harper might want to protect itself against scandals that damage book sales, it’s an extremely mischievous innovation and we urge Harper to reconsider it.

Besides, it could backfire. For who is to say that scandalous behavior cannot actually increase book sales? We’ve seen it happen again and again.  Therefore, if you one day run afoul of Harper’s legal eagles because you left your hanky in the wrong panky, you might consider invoking The Bentley Defense.

What’s The Bentley Defense?  Toni Bentley is a former ballerina who published a memoir entitled The Surrender. It happens that what she surrendered to was the bliss of anal sex.”My ass,” she rhapsodized, “is my very own back door to heaven.”  But instead of causing her book to tank, her graphic descriptions of her predilection had the opposite effect: The Surrender was an international bestseller. Publishers Weekly described it as “wonderfully smart and sexy and witty and moving, a tale of unbounded passion that leads to transcendence.”

If this had been a Harper book, what would they have done about this author with her taboo-shattering parade of iniquity and degeneracy?  Actually we don’t have to speculate, because it was a Harper book!

And what did they do about the author? Send her lots and lots of royalties, we imagine.

Richard Curtis

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8. PUBLISHER’S RIGHTS OF TERMINATION
If (i) Publisher determines that any of the representations of Author set forth in Section 6(a) is false, or (ii) Author breaches the covenants set forth in Sections I(f), I(g), 2(c), or 2(d), or (iii) Author commits a breach of any covenant contained in the Special Provisions section of Part I above for which Publisher is given a right of termination, or (iv) Author’s conduct evidences a lack of due regard for public conventions and morals, or Author commits a crime or any other act that will tend to bring Author into serious contempt, and such behavior would materially damage the Work’s reputation or sales, Publisher may terminate this Agreement and, in addition to Publisher’s other legal remedies. Author will promptly repay the portion of the Advance previously paid to Author, or, if such breach occurred following publication of the Work, Author will promptly repay the portion of the Advance which has not yet been recouped by Publisher.

Are you ready for The Big Bump?

Those of you who read our posting in September (Copyright Asteroid Hurtling Towards Earth) know that The Big Bump is a major copyright event shaping up for the near future. As copyright attorney Lloyd J. Jassin informed us, thanks to a provision of the US Copyright code authors will be able to terminate contracts negotiated in the late 1970s even if those contracts appear to give the publisher rights forever.

“Starting in 2011,” Jassin writes, “the publishing and entertainment industries will be looking at the possibility of thousands of negotiations with copyright owners seeking to recapture their rights. Some call it ‘contract bumping.’ This powerful ‘re-valuation mechanism’ found in the Copyright Act allows authors (and their heirs) to terminate contracts 35-years after the contract date. The termination right trumps written agreements — even agreements which state they are in perpetuity.” [Italics ours]

Though nobody has panicked, the news has begun to percolate and publishing people and their lawyers are beginning to review their old contracts to determine what books are affected and to institute damage control measures.

For publishers the strategy is to commence negotiations with authors and agents now to extend or renew the old contracts or negotiate brand-new ones.  Because e-books and print on demand, two products essential to extending the life of a contract, did not exist pre-1978 (or pre-1998 for that matter), publishers will insist that renewals provide for them.

The big question however is, once authors know they can recapture their old contracts, will they blithely sign their e-book and POD rights away?

Authors who exercise their “bump” right will realize what a treasure the copyright law has bestowed on them.  Why would they bestow it back on their publisher, especially if their publisher is paying a lower e-book royalty than is being offered down the street by some independent e-book publishers. (Full disclosure. E-Reads is down the street.)

Which means that independent e-book publishers might be in for windfalls starting 2013.

Publishers, authors and agents have a lot to think about between now and 2013, and it isn’t too soon to start thinking about it now.

For the full text of Article 203 of the 1978 Copyright Act, the provision that is causing all this turmoil, click here.

Richard Curtis

This is speculation but in a survey conducted by The Street.com more than 37% agreed that Amazon represents the most logical choice” to take over the sinking Barnes & Noble book chain.

“Amazon has been a thorn in Barnes & Noble’s proverbial side since its inception in 1995, when it was solely a purveyor of books,” writes Jeanine Poggi. “B&N has consistently lost market share to its non-bricks-and-mortar rival, which has bested it on lower prices for hardcovers.

“Now the battle has gone purely digital. While Amazon took the lead, launching its Kindle e-reader back in 2007, Barnes & Noble is playing catch up, rolling out an e-bookstore last summer and introducing its Nook e-reader in October 2009.”

We weren’t among the polled but for whatever it’s worth we think it’s an intriguing idea. With all due respect to its recently acquired e-tailer Fictionwise, Barnes & Noble desperately needs a digital component, and Amazon would love to have a brick and mortar presence. What would happen to the Nook?  Well, what happened to the Auk?

For background read Barnes & Noble Succumbs to Digital Disintermediation.

RC

Once again it’s time to play You Be the Agent.

Today’s question is, How much is one line of poetry worth? Not a lot, you say? Suppose you represented the Robert Frost estate and someone requested permission to use the line “And miles to go before I sleep” in an anthology. Still think it’s worth nothing?

That’s the kind of question that comes up daily in every literary agency. But with the introduction of digital technology, decisions that were once fairly cut and dried have become head-spinningly complex. Marc Aronson, in an op-ed piece published in the New York Times, stated the issue cogently: “In order for electronic books to live up to their billing, we have to fix a system that is broken: getting permission to use copyrighted material in new work. Either we change the way we deal with copyrights — or works of nonfiction in a multimedia world will become ever more dull and disappointing.”

What does Aronson mean? “Given that permission costs are already out of control for old-fashioned print,” he writes, “it’s fair to expect that they will rise even higher with e-books. After all, digital books will be in print forever (we assume); they can be downloaded, copied, shared and maybe even translated. We’ve all heard about the multimedia potential of the iPad, but how much will writers be charged for film clips and audio? Rights holders will demand a hefty premium for use in digital books — if they make their materials available in that format at all.”

Aronson thinks it’s high time for a new permissions model grounded in the realities of the digital paradigm. “Instead of paying permission fees upfront based on estimated print runs, book creators would pay based on a periodic accounting of downloads.” Though accounting for sales under this system might at first seem daunting, the micropayment management such as Paypal is already commonplace.
Aronson is onto something. Expect to hear more about it.

Richard Curtis

Every Blogger owes a debt of gratitude to newspapers and magazines. This posting relies on original research and reporting performed by The New York Times.

The Author’s Guild issued a sharp rebuke to publisher John Wiley & Sons for delivering a sort of Trojan Horse to authors.

The “horse” came in the form of a notice to authors who had contracts with newly acquired Bloomberg Press that the company was downwardly adjusting its royalty rates. Buried inside a saccharine (“We are pleased to inform you…”) salutation was a message that Wiley was conforming Bloomberg’s royalty to the rate stipulated in Wiley’s boilerplate – an “adjustment” that would pay the authors 24% and 43% less than they were getting.The authors were invited to sign an amendment.

The Guild’s outrage that authors were being snookered was expressed in unusually strong language. “The contract amendment, which provides no threshold level of sales for a work to be considered in print, essentially grants Wiley a perpetual right in an author’s book for a pittance. The 5% of net receipts royalty rate for print on demand editions is as lowest we have ever seen.” And “This is no way to do business. The letter is shocking from a publisher of Wiley’s stature.” “In our view, Wiley should tear up any signed letters it has received and start over, forthrightly explaining to its new authors the contractual changes it is seeking and how this may affect their income and their right to terminate their publishing contracts.”

We haven’t viewed Bloomberg contracts but assignment language in many publishing contracts guarantees that an acquiring company cannot change contractual terms without the express consent of the author. Signing the amendment would do just that, and the Guild wants to make sure authors know that it is a potential trap.

The full text of the Guild’s notice is below.
Richard Curtis
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Wiley’s Deceptive Letter to Bloomberg Press Authors: “We are pleased to inform you” that we will be slicing your royalties up to 50%

John Wiley & Sons acquired Bloomberg Press, the books division of Bloomberg, in March. At the end of April, it began sending a letter to hundreds of Bloomberg Press authors purporting to inform them “about a few differences in the accounting systems of Bloomberg and Wiley that it will be helpful for you to know about.”

While this sounds innocent enough, it isn’t. If signed by an author, the letter is actually a contract amendment that will materially and adversely affect the royalty rates of many Bloomberg Press authors.

Among other things, this contract amendment would:

1. Change royalty rates based on retail list price to rates based on net receipts. We’ve reviewed several Bloomberg Press contracts. All provide for royalty payments based on the retail list price (although we understand that there may be many based on net receipts). The Wiley letter misleadingly presents this to the author as good news: “We are pleased to inform you that we will be paying your royalties on the net amount received…” This change will, for many authors, effectively slice royalties by up to 50% for some book sales. Wiley’s letter fails to disclose that.

2. Empower Wiley to keep an author’s book in print with a lowball print on demand royalty of 5% of net receipts. (Bloomberg Press had no print on demand program.) The contract amendment, which provides no threshold level of sales for a work to be considered in print, essentially grants Wiley a perpetual right in an author’s book for a pittance. The 5% of net receipts royalty rate for print on demand editions is as low as we’ve seen.

We’ve asked an independent royalty auditor to review the affects of these contractual changes on royalty income. The royalty auditor found reductions of 24% to 43% using actual sales figures and applying Wiley’s amendments. (The precise affect of the amendments will vary by title, depending on particular categories of sales of the work.)

The Authors Guild strongly urges Bloomberg Press authors to not sign this letter without careful consideration. If you have received this letter, consult your agent or a publishing attorney or contact a lawyer in our legal department so you understand precisely how this amendment would affect your rights and royalties. Important: if you have already signed the letter and returned it to Wiley, contact our legal department immediately. Non-Guild members are welcome to contact us as well. All communications will, of course, be held in confidence.

This is no way to do business. The letter is shocking from a publisher of Wiley’s stature. In our view, Wiley should tear up any signed letters it has received and start over, forthrightly explaining to its new authors the contractual changes it is seeking and how this may affect their income and their right to terminate their publishing contracts.

The Authors Guild

If authors are being asked to do the publishers’ job of marketing and publicizing their own books, shouldn’t the publishers pay them for it, as they would pay a staff member or outside publicist?

M. J. Rose thinks so. In fact, she’s beating the drum to promote the idea. “In almost all cases, publishers are making it clear that they expect authors to supplement their marketing/PR effort in various ways and, in some cases, even soliciting the author’s help with both time and yes, money. As a result, today the author’s marketing/PR effort is often equal to or even greater than what the house is doing.”

Authors are subsidizing marketing and PR and but that’s not enough, says Rose, a well known and savvy publicist for authors (as well as for herself). She wants to change the way publishers compensate authors. Read about it in Publishers Must Change the Way Authors Get Paid

RC

Pardon me, but do you have any legal training? I’m thinking of suing someone. My lawyer thinks I’m a crackpot, so I need a second opinion.

Listen to this:

About twenty years ago when I was a volunteer 4th grade teacher I created an adventure aimed at teaching children about government. I instructed the kids to pretend to be on a cruise ship that is blown off course by a storm. They ended up shipwrecked on a tropic island, and in order to survive they had to develop a government.

Fifteen years later, Lost was launched on television and guess what? It’s about a passenger jet that crashes on a topical island. Obviously, to cover their trail they changed my cruise ship into an airplane. Other than that it’s my exact same idea. And look at the similarities! In my story the kids have to organize; On Lost they have to organize. In my story the kids have to eat disgusting things – same as on Lost. So, I’m thinking of suing the producers of Lost for copyright infringement. Do I have a slam-dunk case or what?

Actually, I hadn’t thought of suing until I read that an author named Jordan Scott has brought a lawsuit against bestselling Twilight author Stephenie Meyer alleging copyright infringement. According to Gil Kaufman of MTV. com, Meyer allegedly plagiarized something called The Nocturne written by Scott when was fifteen. She posted it one chapter a time on her website. Here’s what Kaufman writes about Scott’s claim: “Though Scott’s book is set in 15th-century France and details a love affair between a young sorcerer and a teenage girl and Meyer’s book chronicles a doomed teenage love triangle between a human, a vampire and a werewolf set in modern times, Williams said the plot lines and some developments — detailed in more than a dozen examples in the suit — match too closely to be a coincidence.”

It happens every recession.

Anyone who has lived through enough business cycles can predict that whenever there’s a downturn in the economy book publishers are going to attempt to cancel contracts on overdue books. You can also bet they’re going to step up pressure on authors of overdue books to repay advances issued when they signed contracts. Given the double plunge of the national economy and the trade book business, a story by Leon Neyfakh in the New York Observer, Note to Authors: Make Your Deadlines!, comes as no surprise. “Many literary agents are growing increasingly worried that publishers looking to trim their lists will start holding authors to deadlines and using lateness as an occasion to renegotiate advances and, in some cases, terminate contracts altogether,” writes Neyfakh.

Authors and agents will ignore Neyfakh’s cautionary article at their peril: it is absolutely true that late authors are vulnerable to cancellations and demands for refunds. Though arbitrary or vindictive terminations are rare, a breach of deadline removes an author’s most important legal defense against having a late book chopped arbitrarily. And though wholesale cancellations are equally rare, Neyfakh reminds us that the waters are still roiling from HarperCollins’s termination of as many as 100 contracts for tardy books back in 1997. Another reason why authors must either deliver their books on time or work out deadline extensions with their editors – and get them in writing.

If you haven’t taken these measures, don’t despair. There’s plenty you can do to defend yourself. This may be a good example of the saying that the best defense is a good offense. A little attitude might make publishers think twice before pulling the plug on the book you’ve worked on for years – for more years than you contract granted you.

The first thing you need to do remind yourself is that lateness is the medium in which the publishing process is bathed, and publishers are as guilty as authors are. “We breathe late manuscripts and eat late checks and drink late contracts,” I observed on one of those occasions that publishers rattled their sabers about coming after delinquent authors.

However dearly publishers would like to turn authors into automatons, the fact is that they are artists, and artists just don’t live in the same time zone as the suits who expect their publishing companies to generate the predictable cash flow generated by the pantyhose or shoe store divisions of their global conglomerates. It also behooves publishers to remember that professional authors are proud and conscientious people who would rather take a little extra time to get the work right than to turn in crap on deadline. Nor should it be forgotten that authors are as much motivated by self-interest as publishers are: writers don’t get paid until they deliver their manuscripts. So, publishers can rattle sabers all they want: their book will be turned in when it’s turned in, and if that means a day or week or even a month or longer past deadline, they’ll simply have to grin and bear it.

Whatever the suits might expect, most editors understand that late books are more the rule than the exception, and these men and women are patient, tolerant, resigned and (most of the time) good natured about it. They realize that writers are creative people possessed of a somewhat atrophied internal clock. Writers also have lives to live, and stuff happens to them – the same stuff that happens to editors, except that editors collect their paychecks every week when stuff happens, and authors don’t.

For most editors most of the time, a late book isn’t the end of the world. Editors are resourceful; a book that falls out of the spring list will, with some muttering and scrambling, be replaced by another. Sure, there’ll be some awkward patches in their catalogs – “Postponed”, “Delayed”, etc., and some budget considerations will have to be reconfigured – but, short of a late James Patterson or Stephenie Meyer on whose shoulders a year’s profit projections rest, few postponements make a dent in a publisher’s bottom line.

Lateness, then, is an understandable and forgivable quality in authors. In publishers, however, it is less excusable. The internal clocks of publishing companies are precisely calibrated – until it comes to paying money to authors. For most trade book houses, the time between the handshake and the arrival of a contract takes several months, as does the time from execution of that contract to the arrival of the advance due on signing. During which time the author is expected to be working in good faith on the manuscript.

Because the editorial departments of publishing companies are usually separated from the accounting departments (they are often located in different states), editors are seldom aware that their author is hurting for money, at least not until some plaintive cry (or homicidal rant or suicide threat) from that author sends them into a frenzy of phone calls and emails to accelerate the check and “walk it through” the corporate precincts. That the author may have been forced to take on other work to boil the pot until the the publisher finally got around to paying up does not always register on editors and their superior officers.

Though delays in processing contracts and payments are the products of normally slow-moving corporate machinery, those delays are sometimes the result of deliberate policies designed to hold onto money as long as possible. And that is simply deplorable, especially these days when the interest to be earned on withheld funds is neglible. I have never known an author to be deliberately late with a book, but I have known many a publisher to be deliberately, or at least suspiciously, late with a check. I have a standing bet with publishers that an author can write a book faster than the publisher can issue a check. Not surprisingly, nobody has taken me up on it.

And so, when publishers start talking about penalizing authors for late manuscripts, I start talking about charging publishers interest for late checks, or withholding the manuscript one week for every week the check is delayed.

Publishing attorneys are scarcely fountainheads of empathy for the hardships of writers and sympathy for the excuses offered by dilatory authors. So, if you don’t think you’re going to make your deadline, negotiate a comfortable contractual extension. And if you’re worried that your publisher is going to pull the plug on your book, it’s a good idea to keep a record of when checks became due and when they were actually received. That way, you have some recourse to fight back or at least plead that your publisher had some responsibility for your delayed book.

Publishers have a great many weapons at their disposal to recoup money paid to authors who fail to deliver their books on time. Contractual language gives them a kind of lien on the sale of the book to another publisher, and it is therefore hard for an author to get away scot-free even if he or she should manage to find another home for the book. Publishers harass authors with demand letters even though everyone knows the authors have long ago spent the money and don’t have it to repay. And, though no responsible agent will ever condone it, there is some anecdotal support for the likelihood that if an author strings a publisher out long enough, the demand letters will eventually cease and the matter will fall to the bottom of the publisher’s to-do box. For, if the truth be known, publishers realize that it is simply bad public relations to sue an author.

Still, the times being what they are, publishers are much more disposed to give delinquent authors a hard time, and in this regard Neyfakh makes a revealing slip. “Like so many other practices associated with the ‘gentleman’s business’ that the book business used to be”, he writes, “eating advances in the service of good humor has become a luxury most publishers do not indulge in as readily as they once did.”

It was not called the gentleman’s business, Mr. Neyfakh. It was called the gentleman’s profession, and in this incorrect choice of words is all the difference between what publishing was and what publishing has become. But if it truly is a business, publishers need to be more businesslike and pay authors promptly. They might be pleasantly surprised to see the delinquency rate for manuscripts plummet.

Richard Curtis

Every Blogger owes a debt of gratitude to newspapers and magazines. This posting relies on original research and reporting performed by the New York Observer.