This case presents the issue of whether a biographer (Hamilton) of a renowned author (Salinger) made “fair use” of his subject’s unpublished letters. The District Court granted a temporary restraining order in favor of Salinger but subsequently issued an opinion denying a preliminary injunction. 650 F. Supp. 413. (1986). In the District Court’s view, the extent of copying of expressive material entitled to copyright protection was minimal and that such use as Hamilton had made was “fair use” within the meaning of the Copyright Act, 17 U.S.C. § 107 (1982). The Circuit Court reversed and remanded the lower court decision, determining that on balance, the claim of fair use as to Salinger’s unpublished letters failed.