the copy without violating the holder’s exclusive rights.79 Publishers tried to blunt the effects of the first sale doctrine in the analog world by requiring licenses placing restrictions on resale of copies but the courts did not buy their arguments.80 However, licensing of materials is the way of the digital world, rather than outright ownership. Libraries find themselves deprived of the protections given by the first sale doctrine in cyberspace because they are limited to purchasing a service, access to the material, rather than the product itself.