A.A. Hoehling v. Universal City Studios, Inc. 618 F.2d 972 (2d Cir. 1980) Hoehling was a historian who researched the Hindenberg disaster. He published a book (based on several other sources) that blamed the disaster on the work of a saboteur. Later, a fiction writer named Mooney wrote a novel about the disaster that featured a plot and characters similar to Hoehling's research. It was later turned into a movie. Mooeny admitted that he used Hoehling's book as a source for his novel. However, he changed the names of the people and deviated from historical fact on a number of occasions. Hoehling sued Mooney and Universal City for copyright infringement. Hoehling argued that Mooney copied the essential plot of his book. Mooney argued that a plot is an idea, and ideas and not copyrightable as a matter of law. In addition, Mooney argued that historical facts are not copyrightable. Since the historical facts were somewhat unclear, Hoeling argued that his interpretation of the facts was original and therefore copyrightable under 17 U.S.C. §102(a). The Trial Court found for Mooney. Hoehling appealed. The Appellate Court affirmed. The Appellate Court found that Hoehling's allegations encompassed material that is non-copyrightable (historical facts). The Court found that in works devoted to historical subjects, a second author may make significant use of a prior work, so long as they do not bodily appropriate the expression of the original. There is a public policy reason for allowing many people to research and produce accounts of historical events. On the other hand, if a person can't get protection for all their hard work, that would inhibit people from producing accounts.