This chapter focuses on how transformative works in media fandom reflect and refigure the concept of "transformativeness" in copyright fair use law. The Supreme Court found the parody to be a transformative fair use: it was significantly altered in meaning and purpose. In the introduction to the twentieth-anniversary edition of the book, Suzanne Scott claims that Textual Poachers is itself a transformative work, "much like the transformative fan texts at the center of Jenkins's study", even though Jenkins hadn't used the term. The Supreme Court has stated, "The goal of copyright, to promote science and the arts, is generally furthered by the creation of transformative works". Transformativeness was a concept developed by a respected court of appeals judge, Pierre Leval, in an influential article in the Harvard Law Review, "Toward a Fair Use Standard". There have been some interesting legal cases featuring literary remixes and transformative works.