Google follows in the footsteps of Project Gutenberg ( www.gutenberg.org/ ) in scanning out-of-copyright books that have long been out of print and generally unavailable. I wished that Jeffrey Toobin would have acknowledged the work of Project Gutenberg in this valuable task. So far as works in copyright, Toobin might have explored the concerns of authors and publishers in more depth so as to provide an inkling of what the eventual settlement of these lawsuits might look like. For a researcher, the prospect of entering a search term to produce hits from all or nearly all published literature is obviously useful. Not so clear from this article, however, is what a profit-driven corporation such as Google owes to creators for scanning their works and making its parts available to searchers in bits and pieces. Google falls into a different category than the nonprofit, volunteer-driven Project Gutenberg. Creators must be rewarded in order to encourage creation. Google is in a power position with regard to works created by others. Google's argument, recounted by Toobin, that "Google asserts that its use of the copyrighted books is “transformative,” that its database turns a book into essentially a new product" ought to be examined in a lot more depth than Toobin allows. The essence of Google's argument is 'might makes right.' That hardly seems to take into account the effort that goes into book writing, or the wholesale taking of the result of the book-writing effort without compensation to the writer.