laim of sorts, however it has re-emerged in recent years with value of time-sensitive information rising, and the Internets as perfect vehicle to exploit such information The misappropriation principle includes broad prohibitions against overreaching by IP owners, such as the patent misuse doctrine, which exists to"ensure that the patentee does not prosper from an impermissible broadening of the physical or temporal scope of the patent grant. In the copyright context, copyright law provides both civil and criminal sanctions for willful and systematic piracy of copyrighted material. 52 2. Personality/Moral rights rationales Personality or moral rights rationales recognize that creators of works have non- pecuniary interests in preventing the distortion or misattribution of those works by others Moral rights, unlike purely economic regimes, concern how the artist presents his work to the public, and the way he preserves his identification with the work. " 53Moral rights spring from a belief that an artist in the process of creation injects his spirit into the 49 See J THOMAS MCCARTHY. MCCARTHY'S DESK ENCYCLOPEDIA OF INTELLECTUAL PROPERTY (2 Ed. )273 (1995)(noting that many courts, including the Second Circuit Court of Appea limited the INS case to it facts for decades, and that Supreme Court decisions "cast a pall of federal preemption over the misappropriation doctrine. See Bruce P. Keller, Condemned to Repeat the Past: The Reemergence of Misappropriation and Other Common Law Theories of Protection for Intellectual Property, 11 HARV.J. L& TECH 401(1998) See In Re recombinant DNA Technology Patent and Contract Litigation, 850 F Supp. 769, (SD.IND.1994) 02 See 17U. S.C. 506(a)(1999)providing that"a]ny person who infringes a copyright willfully and for purposes of commercial advantage or private financial gain shall be punished.. under federal criminal law). The problem of IP piracy is serious, pervasive and expensive, both domestically and internationally See e. g, Susan Tiefenbrun, Piracy of Intellectual Property in China and the Former Soviet Union and Its Effects Upon International Trade: A Comparison, 46 BUFF. L REV.1,(1998) noting that"It]otal losses to the [U.s. economy due to intellectual property piracy continue to range from $20 billion to $40 billion annually") 1313 claim of sorts,49 however it has re-emerged in recent years with value of time-sensitive information rising, and the Internets as perfect vehicle to exploit such information.50 The misappropriation principle includes broad prohibitions against overreaching by IP owners, such as the patent misuse doctrine, which exists to “ensure that the patentee does not prosper from an impermissible broadening of the physical or temporal scope of the patent grant.”51 In the copyright context, copyright law provides both civil and criminal sanctions for willful and systematic piracy of copyrighted material.52 2. Personality/Moral Rights Rationales Personality or moral rights rationales recognize that creators of works have non￾pecuniary interests in preventing the distortion or misattribution of those works by others. Moral rights, unlike purely economic regimes, “concern how the artist presents his work to the public, and the way he preserves his identification with the work.”53 Moral rights “spring from a belief that an artist in the process of creation injects his spirit into the 49 See J. THOMAS MCCARTHY, MCCARTHY’S DESK ENCYCLOPEDIA OF INTELLECTUAL PROPERTY (2nd Ed.) 273 (1995)(noting that many courts, including the Second Circuit Court of Appeals, limited the INS case to it facts for decades, and that Supreme Court decisions “cast a pall of federal preemption over the misappropriation doctrine.”). 50 See Bruce P. Keller, Condemned to Repeat the Past: The Reemergence of Misappropriation and Other Common Law Theories of Protection for Intellectual Property, 11 HARV. J.L. & TECH. 401 (1998) 51 See In Re Recombinant DNA Technology Patent and Contract Litigation, 850 F. Supp. 769, ____ (S.D.IND. 1994). 52 See 17 U.S.C. 506(a) (1999)(providing that “[a]ny person who infringes a copyright willfully and for purposes of commercial advantage or private financial gain shall be punished…” under federal criminal law). The problem of IP piracy is serious, pervasive and expensive, both domestically and internationally. See e.g., Susan Tiefenbrun, Piracy of Intellectual Property in China and the Former Soviet Union and Its Effects Upon International Trade: A Comparison, 46 BUFF. L. REV. 1, ___ (1998)(noting that “[t]otal losses to the [U.S.] economy due to intellectual property piracy continue to range from $20 billion to $40 billion annually”)