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The clear import of common law copyright cases dealing with personal letters, taken as a whole, is that a recipient has a definite property interest in the writing which is also protectable by the courts. The 'sound morality' language used by the court in Woolsey v. Judd, 11 Super.Ct. (4 Duer) 379, 11 How.Pr. 49 (N.Y.1855), for example, is broad enough to encompass a party in Avery's position. See also Gee v. Pritchard, 36 Eng.Rep. 670, 678 (Ch.1818), which calls 'the ground of property' a firm enough one on which to support the protection of personal rights.

While one court did refuse to recognize, for lack of any precedent, the right of an addressee of a letter to enjoin publication of the correspondence, it specifically noted that no issue of invasion of privacy had been raised by the plaintiff at trial. Knights of the Ku Klux Klan v. International Magazine Co., 294 F. 661 (2d Cir.1923). In contrast, the Wyoming state Supreme Court has declined to distinguish between the author and the recipient of personal letters. It found that both had an interest in enjoining a third person from using those letters 'willfully, and maliciously, ...

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