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quoting a letter

Pursuing David Goodman's posting on owning a physical letter or manuscript
vs. owning the right to reproduce the text or the heart of it: Surely, the
recent (less than crystal clear) legislative provision that "the fact that
a work is unpublished shall not itself bar a finding of fair use" opens
the possibility or likelihood that a brief quote or quotes, for scholarly
purposes, of an unpublished letter or text is fair use. What else could
this provision mean?

Harold Orlans Bethesda, MD