By Annie Weiler
Annie Weiler is a 1L J.D. candidate at the Sandra Day O’Connor College of Law. As the Chair of Line Editing and Cite Checking for the McCarthy Institute, she is particularly interested in the intersection of intellectual property, entertainment, and consumer protection Outside of intellectual property, Annie is interested in professional ethics, federal advocacy, and antitrust.
Introduction
In Oct. 2006, years before platforms like GoodReads and Kindle Unlimited emerged, early fanfiction archive MediaMiner posted a statement about authors who don’t condone fanfiction of their work.[1]
“We at MediaMiner would like to issue a reminder that there are authors and/or publishers who do not allow fan fiction based on their titles,” user Lady MacBeth wrote. “No copyright owner has to allow fan fiction or even tolerate it…This is a right they have as an author or owner of the work.”[2]
Under the post is a roll-call of entities hostile to fanfiction writers in the early 2000s, including Anne Rice, who famously posted “I do not allow fan fiction” on her website,[3] and entire franchises like Archie Comics,[4] a behemoth comic book publisher that put a general kibosh on fanfiction of its subsidiaries.[5] Other early fanfiction platforms, like FanFiction.net[6] and Fanlore,[7] have analog pages listing authors and fandoms banned from their websites.
Meanwhile, Archive of Our Own, today’s fanfiction giant, does not. Should the Archive pull the nearly 60,000 works tagged under “Game of Thrones”[8] to protect its writers because George R.R. Martin’s “not a fan” of fanfiction?[9]
No. Lady MacBeth was wrong. If an author’s work is sufficiently transformative—massive “if”—the new creator, theoretically, has nothing to worry about, even if the original author is a little irritated.[10] Non-commercial, transformative fanfiction falls under fair use,[11] and no court in the United States has ever ruled otherwise.
But even if these early fanfiction archives didn’t have a legal obligation to accommodate a writer’s lukewarm fanfiction attitude, some were still afraid of writers weaponizing the law against them.[12] It’s probably because some writers did. Christine Cuddy, Rice’s attorney, once said, “Even when done on [an] amateur basis…Anne Rice does not want you writing fanfiction, and she has the money to make you stop.”[13] After saying fanfiction is like “selling your children into white slavery,”[14] author Diana Gabaldon called it illegal under “international copyright law.”[15] Warner Bros. and J. K. Rowling were notorious for playing whack-a-mole with Harry Potter fanfiction in a copyright phenomenon now known as the “PotterWar.”[16]
This writer-on-writer copyright striking—friendly fire, so to speak—reflects a broader issue unique to modern creative writing. It made fanfiction seem illegal, relegating it to the social fringes of taboo expression despite ample case law suggesting otherwise. It’s hard to find another form of expression that carries the social stigma of illegality while remaining perfectly legal. To understand this phenomenon, we must first define fanfiction, explore its legal standing, and examine its role in the modern cultural zeitgeist.
Defining Fanfiction
Fanfiction, for our purposes, refers to fan-made, written reinterpretations or extensions of pre-existing media, which retain recognizable elements, like characters or settings, from the original source.[17] Some fanfictions function as prequels or sequels, while others invent alternate universes, dissect character lore, or completely reimagine the canon.[18] Some cling closely to the source material, while others grab a few familiar names and run wild.[19] This medium has birthed everything from irreverent 700,000-word tragedies[20] to 700-word romances,[21] which all coexist under the fanfiction umbrella.
Fair Use and Transformative Works
When internet copyright warriors discuss fanfiction, the term “fair use” gets tossed around with reckless abandon.[22] When they reference fair use, they’re referencing Section 107 of the U.S. Copyright Act, which allows for limited use of copyrighted material without permission.[23] To determine if an individual’s use of copyrighted source material is “fair,” courts weigh four factors: (1) the “purpose and character of the use,” including its commercialization, (2) the “nature of the copyrighted work,” (3) the “substantiality” of the copyrighted work used “in relation to the…whole,” and (4) the “effect of the use” on the source material’s “potential market” or “value.”[24] No individual subfactor makes a use fair or unfair—they must be weighed together.[25]
Sometimes, fair use violations are cut-and-dry. A textbook example is when someone copies a book’s characters or plot beat-for-beat and tries to monetize it.[26] It’s one thing to include a wise, ancient mentor in your commercial book, but swapping in Gandalf from Lord of the Rings comes with legal baggage.[27] For most non-commercial fanfiction, it’s more murky and, like any other fair use dispute, must be evaluated on a case-by-case basis. Considering the medium’s broader principles, objectives, and examples, fanfiction should be presumed to comply with fair use unless a specific work suggests otherwise.
Purpose and Character of the Use
This factor refers to the intended use of a copyrighted work, including whether the use is for commercial gain, criticism, or commentary, as well as how transformative the use is in comparison to the original work.[28] Uses made in bad faith or for commercial purposes are less likely to be considered fair use, while educational, transformative, and statutory purposes such as criticism, comment, and research are more likely to qualify as fair use.[29]
For derivative works, two key factors may determine whether the new work constitutes fair use. The first is whether the fanfiction author profits from their work. Derivative works often fail to meet copyright protection if the new creator seeks to profit from them.[30] Most fanfiction-specific platforms, such as Archive of Our Own, are nonprofit, so fanfiction posted there doesn’t financially benefit its authors.[31] But even on for-profit platforms, like Tumblr or Wattpad,[32] fanfiction is typically considered a labor of love—fans write it because they love the source material, not for pecuniary gain.[33] As a result, this factor generally favors fair use.
The second factor is transformative use.[34] A “transformative” work, as defined by common law, “alter[s] the original with new expression, meaning, or message,” rather than merely replicating the source material.[35] On the contrary, a non-transformative use has “no critical bearing on the substance or style of the original composition, which the alleged infringer merely uses to get attention or to avoid the drudgery in working up something fresh.”[36] The more transformative the “purpose and character” of the new work, the less weight is given to the other factors in the fair use analysis.[37]
In literature, a transformative works can still allude to or appropriate the original’s copyrighted characters or plot without losing transformative status.[38] In Suntrust Bank v. Houghton Mifflin Co., Alice Randall wrote The Wind Done Gone, a novel reimagining Gone with the Wind by Margaret Mitchell.[39] The original plot follows an aristocratic Southern woman navigating romance and the fall of her family’s plantation during the American Civil War and Reconstruction.[40] The Wind Done Gone explicitly sought to challenge the original’s postbellum romanticism by retelling the story from the perspective of Cynara, a recently-freed slave, in a new context with new prose.[41]
The United States Court of Appeals for the Eleventh Circuit vacated the lower court’s injunction, holding The Wind Done Gone constituted transformative use.[42] To emphasize the antebellum absurdity of the original, Randall deliberately mimicked and appropriated its elements. She portrayed white characters as Mitchell did Black characters, gave Black characters “redeeming qualit[ies]” absent from their original counterparts, and made a pointedly critical statement aimed at dismantling the original’s mythology.[43] This approach wasn’t about avoiding the creation of something new but rather about critiquing the original by repurposing its components to make a distinct artistic work.[44] Thus, because The Wind Done Gone was sufficiently transformative because it added new expression to the original, challenging the idealized slavery narrative in Gone with the Wind.[45]
Imparting transformative purposes, commentary, or criticism on an existing canon is the point of fanfiction.[46] It is, by definition, a “what if?” reinterpretation of a canon. By reimagining the source material, fanfiction inherently comments on or criticizes the original’s meaning or portrayals, shifting it from a derivative form of expression to a completely legal creative exercise. Even the aforementioned 700-word drabbles can impart this new purpose—they might imagine a character sucked into a multidimensional portal discovering a national tragedy that occurred in his absence,[47] or consider what might happen if the will-they-won’t-they couple finally got together and how their dynamic might evolve.[48] These stories serve purposes, commentary, or criticism distinct from the original intent—they are transformative.[49]
The way it explores the canon can vary depending on its source. A Marvel fanfiction might describe an unnamed doctor assigned to oversee the Winter Soldier’s reconditioning as she struggles with her job’s dehumanizing nature.[50] A Stranger Things fanfiction might consider the era’s racism from the perspective of a Black child, exploring the conflict between her disdain for her environment and her desire to protect it from the supernatural chaos that threatens it.[51] An author could expose Harry Potter’s entrenched pureblood caste system and its similarities to the British aristocracy, all through a Hermione Granger and Ron Weasley romance.[52]
Therefore, the secret sauce to fair use compliance for fanfiction authors is adding new characters, situations, commentary, or criticism—that is, presenting the original story in such a way that it imparts a new message—while refusing any compensation for it. While claiming that all fanfiction is fair use complaint would be silly, the fanfiction that merely retells the canon without imparting a unique message is fundamentally not fanfiction. Since fanfiction often aims to transform the canon in noncommercial settings, much of it is likely to fall under this protection.
Nature of the Copyrighted Work
This factor merely recognizes that some “works are closer to the core of intended copyright protection than others” and “that fair use is more difficult to establish when the former works are copied.”[53] In cases where the new work must “copy publicly-known, expressive works” to make its point or achieve its goal, this factor is unlikely to separate “the fair use sheep from the infringing goats.”[54] Because fanfiction inherently relies on elements from its source, this factor is given little weight in assessing its fair use.[55] Thus, while this factor doesn’t weigh in favor of fanfiction copyright protection, it doesn’t weigh against it.
Amount and Substantiality of the Portion Used
This factor is fairly straightforward—it evaluates the extent to which the original work was used to create the new one.[56] If the amount used is necessary to achieve the work’s transformative purpose, then this factor becomes less significant in the fair use analysis.[57]
New creators don’t need to take as little as functionally possible for their new work.[58] Rather, the Supreme Court recognizes that a work commenting on another usually needs more than a “fleeting evocation of an original” to make its critical, humorous, or otherwise additive point.[59] In some situations, “extensive use,” meaning use beyond the bare minimum to conjure up the original, can still be fair use, provided it “builds upon the original.”[60]
Fanfiction writers do just this: they take an existing canon, reference characters and events as necessary, and fill in the what-if gaps as required by their reimagined narrative.[61] Whether they minimally or extensively reference the material is irrelevant so long as they transform the source in a meaningful way, whether through critical commentary, humor, or new creative elements, rather than simply replicating it. An author might only use characters from Adventure Time, ditching the rest of the canon to make an alternate-universe college storyline.[62] They might draw from The Office‘s relationships, characters, and history up to season four to craft a fake-dating plot, leaving the lore from subsequent seasons behind.[63] They may reference full scenes, the ensemble cast, and extensively draw from the Star Wars franchise more generally to create a post-canon Andor fanfiction that delves into the trauma inherent in rebellion.[64] All of these could theoretically constitute fair use depending on their execution. Regardless of the approach, as long as the fanfiction incorporates the necessary elements to tell the story without unnecessary excess, this factor will likely favor fair use.
Effect on the Market Value of the Original
This factor considers whether allowing the new work will decrease the demand for the original by serving as a “market substitution.”[65] In a fanfiction context, this simply refers to whether the fanfiction will replace the original work.
There’s no evidence to suggest that fanfiction does anything other than inflate the original’s market value, functioning as a “form of free advertising”[66] that keeps fans engaged during content gaps. The Organization for Transformative Works, a self-described “fan-run nonprofit dedicated to the preservation of fanworks,”[67] contends that fanfiction represents “the acknowledged or obvious borrowing of story elements to tell a new story” and thus cannot substitute the original.[68] Instead of competing with the original creator, OTW asserts that fanfiction writers aim to “promote” the original work by fostering “vibrant and active communities” around it.[69]
This is probably true. Take Stranger Things, a television show following residents of the fictitious Hawkins, Indiana,[70] which has seen a surge in Tumblr activity even though it’s been two years since the latest release.[71] Without canon content to keep fans engaged, it’s hard to understand the recent influx of Stranger Things posts—unless you find the near-constant fanfiction about Steve Harrington and Eddie Munson,[72] making them one of the most popular fanfiction pairings of the past year[73]—even though they didn’t have any romantic connection in the show.[74]
Similar phenomena exist with Supernatural, another television show whose final episode aired in 2020,[75] saw its non-canon ship between Castiel and Dean Winchester remain one of the most popular pairings on Archive of Our Own in 2024.[76] Similarly, House M.D., a television show whose final episode aired over a decade ago in 2012,[77] surged in Tumblr popularity in 2024,[78] coinciding with a sharp influx of House M.D. fanfiction about James Wilson and Gregory House.[79]
For fan communities to remain active, something needs to fill the space between releases of shows, movies, books, or music, and fanfiction plays that role.
Fanfiction and the Cultural Zeitgeist
While it seems silly to make such a fuss about protecting a random teenager’s Minecraft fanfiction, cultural attitudes that dismiss fanfiction as illegal actually do discourage authors and deter them from publishing their work online.[80] Much of this legal discourse can be traced back to this idea that “no copyright owner has to allow fan fiction,”[81] an idea that only exists because of the liberal, baseless threats against fanfiction writers by established copyright holders.
“Fan fiction is derivative,” user Alchemistys wrote last year. “It is not a replacement for published works, for original fiction, or for real literature.”[82]
“[Fanfictions] are copies of art already established; you didn’t have the guts, nor the creativity to come up with this stuff yourself, hence why you’re not in control of canon stories,” user his-most-beautiful-nightmare wrote several years ago. “How can you be more important than the person or people who gave you the structure you’re (technically) plagiarizing?”[83]
So even without legal success, these established copyright holders strong-arming less enfranchised groups with empty legal threats succeeded at making fanfiction seem “shameful and weird.”[84] These copyright strikes made fanfiction seem “derivative and therefore inferior,”[85] thus undermining its social legitimacy, even if its legal legitimacy remains intact. This narrative or social atmosphere outlasted the cases themselves, demonstrating how the law can be used (or abused) to shape what is right or wrong.
And this isn’t a good thing. As a medium, fanfiction has a unique cultural value, and baseless copyright claims not only devalue this contribution but have a chilling effect on artistic expression. If copyright’s purpose is to protect a creator’s exclusive right to their works and promote socially-valuable progress, allowing established copyright holders using copyright for a vaguely symbolic social purpose rather than actually stop infringement is fundamentally anti-creator and therefore anti-copyright. Allowing creators to weaponize copyright like they did against fanfiction in the early 2000s “can harm the public without [providing] a corresponding gain” by suppressing “valuable social commentary [or] cultural expression” that could otherwise enrich public discourse.[86]
Reflecting on weaponized copyright assertions is inherently speculative, but maybe there’s room to implement mechanisms that filter out baseless copyright claims before they reach public perception, sparing niche online communities from unwarranted PR crises and ensuring that socially valuable works remain accessible and protected.
This “purpose of copyright” argument, of course, rests on the premise that fanfiction is socially valuable. Some might scoff at fanfictions like “Big Boss,” a crossover fanfiction between The Avengers and Minions,[87] and argue that such works hardly contribute to social progress. They may say that whether we militantly defend legal and social protection of these works isn’t important for our intellectual progress, artistic expression, or community.
But this belief that fanfiction lacks intrinsic social value narrowly, and mistakenly, focuses on its product—the final story—while overlooking the benefits society reaps by allowing prospective authors or those merely looking for a create outlet to practice their writing skills in a low-stakes environment. It’s an indisputable fact that a substantial number of modern authors, whether Andy Weir or S.E. Hinton, began their careers in fanfiction.[88] It’s not hard to understand why: fanfiction boasts a low-stakes, supportive community where young authors can hone their storytelling skills, add layers of complexity, and experiment with new tropes, voices, and settings within an established framework.[89]
Beyond skill development, fanfiction’s vibrant online community, which produces hundreds of thousands of stories each year, provides a low-stakes, supportive space for readers and writers to connect with like-minded people and form friendships worldwide.[90] This is particularly important for non-heterosexual users, who were 23.7 times more prevalent in an Archive of Our Own survey than in the general U.S. population, and non-cisgender users, who were over 55 times more prevalent in the survey.[91] By fostering belonging and expression for those often marginalized in mainstream spaces, fanfiction is more than a creative outlet or a chance to improve writing—it’s a vital sanctuary for underrepresented people to explore their individuality and find community.
Fanfiction, therefore, is culturally, academically, and artistically essential for nurturing new talent, and these writers deserve the copyright protections to which they’re entitled and a place to safely experiment without wading through copyright code. By protecting fanfiction, copyright law is doing exactly what it should: protecting those developing analytical, communicative, and emotional skills. Even if they don’t become a professional author and write the next The Outsiders, these writers fill our most vital professions with the skills they learn today. This is what creates progress; this is what copyright protects.
Conclusion
The sheer weight of cultural attitudes—particularly the pervasive “this is illegal” mindset—has done more to stifle modern creative expression than any actual legal ruling. The real irony is that these claims of fanfiction being “derivative” or “inferior”[92] are entirely fueled by copyright holders who’ve taken full advantage of vague and baseless legal threats to create a climate of fear and shame around fan-created works. This isn’t about protecting a creator’s rights; it’s about wielding copyright like a social tool to suppress a medium that has become culturally essential to countless emerging voices looking for a low-stakes space to experiment and grow intellectually.
By protecting fanfiction writers from overzealous copyright assertions, we’re actually doing exactly what copyright is meant to do—fostering creative expression and encouraging cultural innovation. So, while it’s easy to dismiss a two-hundred-thousand-word fanfiction about Jackson Avery from Grey’s Anatomy[93] as an exercise in nonsense, it’s not just “fun.” It’s the kind of fun that can lead to real artistic growth, social progress, and the next big thing—or, at the very least, a delightfully creative way to kill a few hundred hours.[94]
[1] Lady MacBeth, Authors/Publishers Who Do Not Allow Fan Fiction, MediaMiner (Oct. 8, 2006), https://www.mediaminer.org/blog/index.php?%2Farchives%2F23-AuthorsPublishers-Who-Do-Not-Allow-Fan-Fiction.html [https://web.archive.org/web/20141001222106/].
[2] Id.
[3] Gita Jackson, Anne Rice Really Hated When People Made Her Characters Bone, VICE (Dec. 13, 2021), https://www.vice.com/en/article/anne-rice-really-hated-when-people-made-her-characters-bone/.
[4] Guidelines, FanFiction.Net, https://www.fanfiction.net/guidelines/ (last visited Dec. 27, 2024).
[5] Fanwork Ban, Tropedia, https://tropedia.fandom.com/wiki/Fanwork_Ban (last visited Dec. 30, 2024).
[6] FanFiction.Net, supra note 3.
[7] Professional Author Fanfic Policies, Fanlore, https://fanlore.org/wiki/Professional_Author_Fanfic_Policies (last visited Dec. 29, 2024)
[8] Game of Thrones (TV), Archive of Our Own, https://archiveofourown.org/tags/Game%20of%20Thrones%20(TV)/works (last visited Dec. 29, 2024).
[9] Dan Selcke, George R.R. Martin: “I’m Not a Fan of Fanfiction.”, Winter is Coming (Nov. 10, 2019), https://winteriscoming.net/2019/11/10/george-rr-martin-fanfiction-explanation/.
[10] Jennifer Kopp, Is Fanfiction Legal?, N.Y.U. J. Intell. Prop. & Ent. L. Blog (Apr. 28, 2021), https://jipel.law.nyu.edu/is-fanfiction-legal/.
[11] Id.
[12] E.g., Lady Macbeth, supra note 1.
[13] Jackson, supra note 2.
[14] Diana Gabaldon, Comment to Firefly! Fanfic!, Compuserve (Feb. 20, 2008), https://webcitation.org/6TEU6QXTb.
[15] Diana Gabaldon, Fan-Fiction and Moral Conundrums, Voyages of the Artemis (May 3, 2010), http://voyagesoftheartemis.blogspot.com/2010/05/fan-fiction-and-moral-conundrums.html [https://web.archive.org/web/20100507173749/].
[16] PotterWar, Fanlore (July 2, 2024), https://fanlore.org/wiki/PotterWar.
[17] Rose Simpson, What is Fanfiction and Is It Worth Reading?, New Haven Free Public Library, https://nhfpl.org/what-is-fanfiction/#:~:text=Fanfiction%2C%20also%20called%20fanfics%2C%20are,creative%20with%20their%20story%20concepts (last visited Dec. 27, 2024).
[18] Id.
[19] Id.
[20] E.g., Collateral Hearts, Archive of Our Own, https://archiveofourown.org/works/59641396 (last visited Dec. 27, 2024).
[21] E.g., Holiday Decorations & Mistletoe, Archive of Our Own, https://archiveofourown.org/works/61714909 (last visited Dec. 27, 2024).
[22] E.g., u/Consistent_Bread6032, Is Fanfiction Legal?, Reddit, https://www.reddit.com/r/FanFiction/comments/vf1h4s/is_fanfiction_legal/ (last visited Jan. 12, 2025).
[23] 17 U.S.C.A. § 107 (West).
[24] Id.
[25] Fair Use, Copyright Information at Penn State, https://copyright.psu.edu/copyright-basics/fair-use/#:~:text=First%20Factor:%20Purpose%20and%20Character,important%20of%20the%20four%20factors (last visited Jan. 12, 2025).
[26] Is Fanfiction Legal?, NovelPad, https://novelpad.co/blog/is-fanfiction-legal (last visited Dec. 27, 2024).
[27] Safi Bugel, Copyright Claim Against Tolkien Estate Backfires on Fanfiction Author, The Guardian (Dec. 18, 2023) https://www.theguardian.com/books/2023/dec/18/copyright-claim-against-tolkien-estate-backfires-on-lord-of-the-rings-fanfiction-author?.
[28] Fair Use, supra note 22.
[29] Id.
[30] Id.
[31] About the OTW, Archive of Our Own, https://archiveofourown.org/about (last visited Jan. 12).
[32] Hayley C. Cuccinello, $400M Fiction Giant Wattpad Wants To Be Your Literary Agent, Forbes (Sep. 24, 2018) https://www.forbes.com/sites/hayleycuccinello/2018/09/24/400m-fiction-giant-wattpad-wants-to-be-your-literary-agent/; Aries Dutta, Tumblr Business Model | How Does Tumblr Make Money?, Feedough (Apr. 25, 2023) https://www.feedough.com/how-does-tumblr-make-money-tumblr-business-model/#google_vignette.
[33] Fanworks, Fair Use, and Fair Dealing, Organization for Transformative Works (Mar. 1, 2018) https://www.transformativeworks.org/fanworks-fair-use-and-fair-dealing/.
[34] Campbell v. Acuff-Rose Music, Inc., 510 U.S. 569, 570 (1994).
[35] Id.
[36] Id. at 579.
[37] Id.
[38] Suntrust Bank v. Houghton Mifflin Co., 268 F.3d 1257, 1266 (11th Cir. 2001).
[39] Id. at 1259.
[40] Id. at 1270.
[41] Id.
[42] Id. at 1276.
[43] Id. at 1271.
[44] Id.
[45] Id.
[46] Casey Lawrence, The Truth About Fanfiction, Medium (Feb. 4, 2022), https://medium.com/technical-excellence/the-truth-about-fanfiction-6c07a64a96b2.
[47] Ford Learns About 9/11, Archive of Our Own, https://archiveofourown.org/works/58014481 (last visited Jan. 12, 2025).
[48] Laundering Clothes, Archive of Our Own, https://archiveofourown.org/works/23406976 (last visited Jan. 12, 2025).
[49] Fair Use, supra note 22.
[50] Soldat, Archive of Our Own, https://archiveofourown.org/works/10522041 (last visited Dec. 30, 2024).
[51] We Can’t Say What We’ve Seen (And We’re Not Little Children), Archive of Our Own, https://archiveofourown.org/works/40358241 (last visited Dec. 30, 2024).
[52] The Veiled Boy, Archive of Our Own, https://archiveofourown.org/works/55498027 (last visited Dec. 30, 2024).
[53] Campbell, 510 U.S. at 586.
[54] Id.
[55] Suntrust Bank, 268 F.3d at 1271.
[56] Fair Use, supra note 25.
[57] Id.
[58] Suntrust Bank, 268 F.3dat 1273.
[59] Elsmere Music, Inc. v. National Broad’g Co., 623 F.2d 252, 253 n. 1 (2d Cir.1980)
[60] Id.
[61] Simpson, supra note 14.
[62] C’s Get Degrees, Archive of Our Own, https://archiveofourown.org/works/6139491 (last visited Jan. 12, 2025).
[63] It’s Just Dinner, Archive of Our Own, https://archiveofourown.org/works/29384400 (last visited Jan. 12, 2025).
[64] Take Me Home, Archive of Our Own, https://archiveofourown.org/works/42397527 (last visited Jan. 12, 2025).
[65] Campbell, 510 U.S. at 593.
[66] Sadie Trombetta, Why Fanfiction Is Good For Readers — And Writers (Mar. 3, 2017),
https://www.bustle.com/p/why-fanfiction-is-a-good-thing-for-writers-readers-39359 (last visited Dec. 30, 2024).
[67] Frequently Asked Questions, Organization for Transformative Works, https://www.transformativeworks.org/faq/ (last visited Dec. 30, 2024).
[68] Id.
[69] Id.
[70] Jack Seale, Stranger Things 4 Review – Bigger, Better and More Gruesome Than Ever (May 27, 2022), https://www.theguardian.com/tv-and-radio/2022/may/27/stranger-things-4-review-bigger-better-and-more-gruesome-than-ever (last visited Dec. 30, 2024).
[71] TV Shows, Tumblr (Dec. 3, 2024), https://fandom.tumblr.com/post/768877358125088768/tv-shows (last visited Dec. 30, 2024).
[72] u/Fanficionado, AO3 Ship Stats: 2024, Reddit https://www.reddit.com/r/AO3/comments/1db6oxn/ao3_ship_stats_2024_new_alltime_top_100_and_top/ (last visited Dec. 30, 2024).
[73] Ships, Tumblr (Dec. 4, 2024), https://fandom.tumblr.com/post/768945954998140928/ships.
[74] Harriet Mitchell, Stranger Things Season 4 Star Addresses Fan Reaction to Eddie and Steve’s Bromance (July 10, 2022), https://www.digitalspy.com/tv/a40566060/stranger-things-season-4-eddie-steve-bromance/ (last visited Dec. 30, 2024).
[75] Carry On, Supernatural Wiki, https://supernatural.fandom.com/wiki/Carry_On (last visited Jan. 14, 2024).
[76] u/Fanficionado, supra note 72.
[77] Everybody Dies, House Wiki, https://house.fandom.com/wiki/Everybody_Dies (last visited Jan. 14, 2024).
[78] TV Shows, Tumblr (Dec. 4, 2024), https://fandom.tumblr.com/post/768877358125088768/tv-shows.
[79] Ships, supra note 64.
[80] E.g., Fanfiction Legality – Should Potential New Authors Fear It?, Reddit, https://www.reddit.com/r/FanFiction/comments/kyvv1f/fanfiction_legality_should_potential_new_authors/ (last visited Jan. 12, 2025); Is Fanfiction Illegal?, Reddit, https://www.reddit.com/r/FanFiction/comments/ofnevq/is_fanfiction_illegal/ (last visited Jan. 12, 2025).
[81] Lady Macbeth, supra note 1.
[82] alchemistys, [Post about fanfiction and consumerism], Tumblr (Aug. 29, 2023), https://www.tumblr.com/alchemistys/727028892195504130/i-mean-fanfiction-can-be-fun-and-shit-but-it-is?source=share.
[83] his-most-beautiful-nightmare, [Post about fanfiction and originalism], Tumblr (Oct. 5, 2021), https://www.tumblr.com/his-most-beautiful-nightmare/664234133060550656/i-think-its-funny-that-many-fanfic-writers-call?source=share.
[84] u/No-Manufacturer5834, Why is Writing Fanfiction So Shameful and Weird to Other People?, Reddit, https://www.reddit.com/r/FanFiction/comments/jiqxx8/why_is_writing_fanfiction_so_shameful_and_weird/ (last visited Dec. 30, 2024).
[85] u/AdmiralAkbar1, Comment to Why is Writing Fanfiction So Shameful and Weird to Other People?, Reddit, https://www.reddit.com/r/FanFiction/comments/jiqxx8/why_is_writing_fanfiction_so_shameful_and_weird/ (last visited Dec. 30, 2024).
[86] Cathay Y. N. Smith, Weaponizing Copyright, 35 Harv. J. L. & Tech. 194, 206-207 (2021), https://jolt.law.harvard.edu/assets/articlePDFs/v35/4.-Smith-Weaponizing-Copyright-Corrected.pdf.
[87] Big Boss, Archive of Our Own, https://archiveofourown.org/works/11692998 (last visited Dec. 30, 2024).
[88] Cclogston, 21 Authors Who Write Fanfiction, Lawrence Public Library (May 17, 2019), https://lplks.org/blogs/post/21-published-authors-who-write-fanfiction/.
[89] See Simpson, supra note 14.
[90] Id.
[91] Lauren Rouse & Mel Stanfill, Over*Flow: Fan Demographics on Archive of Our Own, Flow(Feb. 22, 2023), https://www.flowjournal.org/2023/02/fan-demographics-on-ao3/#:~:text=Respondents%20who%20listed%20more%20than,and%204%25%20in%20North%20America.
[92] u/AdmiralAkbar1, supra note 61.
[93] What Would Be Left of Them, Archive of Our Own, https://archiveofourown.org/works/14779256/chapters/34181672, (last visited Dec. 30, 2024).
[94] E.g., u/_Yue_, How Long Does it Take for You to Write Fanfiction?, Reddit, https://www.reddit.com/r/FanFiction/comments/9zbzyg/how_long_does_it_take_for_you_to_write_fanfiction/ (last visited Dec. 30, 2024).