The third fair use factor is "the amount and substantiality of the
portion used in relation to the copyrighted work as a whole. 223 The
qualitative "value" of the expression to the original work receives
consideration along with the quantitative amount.224 In general, this
provides the creator of a second work some limited leeway to use a
small amount of expression from a copyright-protected work as long
as the use does not take the core or heart of the original work. In
copyright policy terms, the ability to use a limited amount of
copyrighted material supports an overall increase in authorial
productivity while attempting to avoid the interference with monetary
and non-monetary rewards to copyright owners that might occur with