 The law of ideas is typically applied in cases where individuals produce ideas and submit them to corporations expecting to be compensated. In certain cases, when these ideas are used by the corporation (or anyone) without authorization, compensation may be required. Before concluding that an author has property rights to her idea(s), courts require the idea(s) to be novel or original (Murray v. National Broadcasting, 844 U.S. F2d 988 (Second Cir. 1988)) and concrete (Hamilton Nat’l Bank v. Belt (D.C. Cir. 1953)). Compensation is offered only in cases of misappropriation (Sellers v. American Broadcasting Co. (11th Cir. 1982)).