EDITORIAL DEPARTMENT maintained until publication by or with the consent of the author, and that any other person publishing the work or infringing the author's exclusive privilege was liable to an injunction and to an order for delivery up of the pirated copies or infringements. But now, in addition to this, the Court of Appeal, affirm ing Mr. Justice Swirifen-Eady's decision in Mansell v. The Valley Printing Company, has held that the common-law right of the author is a full and complete right of property entitling him not only to equitable relief but also to damages against an innocent person who pub lishes not the work itself but a pirated copy of the author's unpublished work. In other words, there is a full right of property in the idea when " detached from the manuscript or canvas or any other physical existence what soever," as complete as the right in a personal chattel. Lord Blackburn defined conversion
in the leading case of Hollins v. Fowler as "any act which is an interference with the dominion and right of property of the plaintiff," and now it seems that conversion is applica ble to incorporeal rights as well as to physical property, and that the owner of an unpublished work has the same right to damages from any person, however innocent, interfering with his dominion as the owner of a registered copyright to which the statute has expressly attached the full rights of property. The extension of the author's property rights is unexceptionable in point of law, and, viewed from the ground of public policy, it may be commended in these days, when there are so many attempts made by the unscrupulous to appropriate original works under the rather thin excuse of making them popular while really enriching themselves at the expense of the authors.
