 While much of the economic literature in this area focuses on patents, similar points can be made with respect to copyright. With the ease of copying and distribution afforded by modern digital networks, content creators would seem to be at a serious disadvantage compared to copiers. Without copyright there would be nothing to stop copiers from simply copying movies, books, articles, and music and selling, trading, or allowing others to make free copies. Michael Smith and Rahul Telang, argue that piracy harms both producers and consumers by undermining the income streams of producers, resulting in less content being created (Smith &amp; Telang 2016). Sean O’Connor notes, “it should be clear that no one would invest without some appropriation mechanism that would provide them with a favorable return on their investment through the monetization of the commercialized goods or services. If they cannot see a way to get such a return, they will not make the investment” (O’Connor 2015).