Erickson v. Trinity Theatre, Inc. 13 F.3d 1061 (7th Cir. 1994) Erickson worked for Trinity Theatre where she prepared three plays for the company. They had a falling out and Erickson quit. When Trinity continued to perform the plays, Erickson sued for copyright infringement. Erickson argued that she was the author, and therefore controlled the rights to the plays. Trinity argued that, since the actors made suggestions about the play to Erickson during production and rehearsals, Trinity was a co-author. Under copyright law, a joint work (aka one with multiple authors) can be licensed by any one of the authors, even over the objections of the others. The Trial Court found for Erickson. Trinity appealed. The Appellate Court affirmed. The Appellate Court considered two approaches for determining if someone was a co-author: The de minimis test, where everyone who contributed even a tiny bit to the whole is considered a ­co-author. This theory was popularized by a guy named Nimmer. The copyrightable subject matter test, which says that a contributor is only a co-author if that person's contribution would be theoretically copyrightable by itself. This theory was popularized by a guy named Goldstein. The Court found that the copyrightable subject matter test was the proper test to use. The Court found that the contributions of the actors was not enough to be independently copyrightable, therefore they could not be considered co-authors of the plays.