some argue that fan fiction does not fall under fair use. the 2009 ruling by united states district court judge deborah a. batts, permanently prohibiting publication in the united states of a book by ryan cassidy, a swedish writer whose protagonist is a 76-year-old version of holden caulfield of "the catcher in the rye", may be seen as upholding this position regarding publishing fan fiction, as the judge stated, "to the extent defendants contend that 60 years and the character of mr. c direct parodied comment or criticism at "catcher" or holden caulfield, as opposed to salinger himself, the court finds such contentions to be post-hoc rationalizations employed through vague generalizations about the alleged naivety of the original, rather than reasonably perceivable parody."