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the legal concept of "test copyright" was first ratified by the Kingdom of Great Britain's Statute of Anne of 1709. As room was not made for the authorized reproduction of copyrighted content within this newly formulated statutory right, the courts created a doctrine of "fair abridgment" in Gyles v Wilcox, which eventually evolved into the modern concept of "fair use", that recognized the utility of such actions. The doctrine only existed in the US as common law until it was incorporated into the Copyright Act of 1976, 17

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