If a lender's fees and interest are in a standard range, they might be viewed as analogous to the landlord that gets a monetary sum fixed up-front without other benefit, which has been found to be not sufficient. n232 In Deutsch v. Arnold, n233 the Second Circuit held that a landlord who received a fixed sum rental ($ 200 in 1938 dollars, approximately $ 3,000 in 2008 dollars n234), but was entitled to receive and in fact received nothing in [*119] relation to the acts of infringement was not enough to make her a vicarious infringer. n235 The Humphreys court n236 is right in the sense that the ease at which the principal, interest, and fees are actually collected might depend on the financial success of the direct infringer. Nevertheless, like the rental in Deutsch, n237 the normal fees and interest owed to a lender in an ordinary transaction will not depend on the amount of infringement. The Deutsch landlord's collection of rents was also dependent on the financial success of the direct infringer, but liability was not found. n238 Given the diversity of lenders, this discussion is not complete. Hybrid and complex financing will lead to myriad permutations on the spectrum of lending. This paper therefore cannot cover all of them. Nevertheless, three important types are described below to start the discussion and act as guideposts.