work and that the artists personality, as well as the integrity of the work, should therefore be protected.. Even assuming full economic compensation for use of a work, personality rationales permit creators to enjoin uses of their works that creators would find offensive the" essence of a moral-rights injury lies in the damage caused to the authors personality, as that personality is embodied in the fruits of her creation. 22 In French copyright law, moral rights include the right to attribution, the right to integrity, the right to divulgation, and the right to modification. In contrast to U. S copyright law, for example, the right of integrity"gives a creator the legal power to exercise control over a work, even after it has been sold or transferred, and to prevent its alteration, distortion or mutilation".However, U.S. law has long been remarkably resistant to directly incorporating moral rights into intellectual property law. The Visual Artists Rights Act of 1990, which protects limited edition works of fine art"is the only recognition of noneconomic based artist's rights by Congress since the United States Joined the Berne Convention 59 Further, it has been noted that there is significant 53 See Cheryl Swack, Safeguarding Artistic Creation and the Cultural Heritage: A Comparison of Droit Moral Between france and the United States, 22 COLUM.-VLA J L. ARTS 361(1998) 54 See Carter v Helmsley-Spear, Inc, 71 F3d 77,_(2d Cir. 1995), cert. denied.S.(1996) See roberta rosenthal Kwall, Preserving Personality and Reputational Interests of Constructed Personas Through Moral Rights: A Blueprint for the Twenty-First Century, 2001 U. ILL. L. REV. 151, 158 (2001) 56 See Michael B Reddy, The Droit De Suite: Why American Fine Artists Should Have a Right to a Resale oyalty,15LoY.L.A.ENT.LJ.509,513-15(1995) See e.g. Note, Carl H Settlemeyer, Between Thought and Possession: Artist's "Moral Rights"and Public Access to Creative Works, 81 GEO. L.J. 2291, 2306(1993) (noting that"[]he American copyright system has, until quite recently, refused to recognized the moral rights of authors per se." ). As a result, protection of personality interests has been forced to come in through the"backdoor", via private agreement or through contrivance of 43(a)of the Lanham Act prohibiting false endorsement and sponsorship14 work and that the artist’s personality, as well as the integrity of the work, should therefore be protected…”54 Even assuming full economic compensation for use of a work, personality rationales permit creators to enjoin uses of their works that creators would find offensive: the “essence of a moral-rights injury lies in the damage caused to the author’s personality, as that personality is embodied in the fruits of her creation.”55 In French copyright law, moral rights include the right to attribution, the right to integrity, the right to divulgation, and the right to modification.56 In contrast to U.S. copyright law, for example, the right of integrity “gives a creator the legal power to exercise control over a work, even after it has been sold or transferred, and to prevent its alteration, distortion or mutilation”.57 However, U.S. law has long been remarkably resistant to directly incorporating moral rights into intellectual property law.58 The Visual Artists Rights Act of 1990, which protects limited edition works of fine art “is the only recognition of noneconomic based artist’s rights by Congress since the United States joined the Berne Convention.”59 Further, it has been noted that there is significant 53 See Cheryl Swack, Safeguarding Artistic Creation and the Cultural Heritage: A Comparison of Droit Moral Between France and the United States, 22 COLUM.-VLA J.L. & ARTS 361 (1998). 54 See Carter v. Helmsley-Spear, Inc., 71 F.3d 77, __(2nd Cir. 1995), cert. denied ___ U.S. ___(1996). 55 See Roberta Rosenthal Kwall, Preserving Personality and Reputational Interests of Constructed Personas Through Moral Rights: A Blueprint for the Twenty-First Century, 2001 U. ILL. L. REV. 151, 158 (2001). 56 See Michael B. Reddy, The Droit De Suite: Why American Fine Artists Should Have a Right to a Resale Royalty, 15 LOY. L.A. ENT. L.J. 509, 513-15 (1995). 57 Id. 58 See e.g. Note, Carl H. Settlemeyer, Between Thought and Possession: Artist’s “Moral Rights” and Public Access to Creative Works, 81 GEO. L.J. 2291, 2306 (1993)(noting that “[t]he American copyright system has, until quite recently, refused to recognized the moral rights of authors per se…”). As a result, protection of personality interests has been forced to come in through the “backdoor”, via private agreement or through contrivance of 43(a) of the Lanham Act prohibiting false endorsement and sponsorship