treat transactions of this kind as the sale or use of tangible personal property or as something else. Faced with a virtually identical interpretative regulation (although substantially different tax provisions), California has resolved the matter by reference to the single consideration of physical usefulness. See Preston v. State Bd. of Equalization, 25 Cal.4th 197, 105 Cal.Rptr.2d 407, 19 P.3d 1148, 1158 (2001) ("Together, these decisions establish that any transfer of tangible property physically useful in the manufacturing process is subject to sales tax even though the true object of the transfer is an intangible property right like a copyright.") (emphasis in original); see also Simplicity v. State Bd. of Equalization, 27 Cal.3d 900, 167 Cal.Rptr. 366, 615 P.2d 555, 562 (1980) (<HOLDING>). Boulder urges that its tax provisions be
holding that plaintiffs had standing because they were directly affected by the laws and practices against which their complaints were directed holding that tort claims were arbitrable because they arose out of and were related to contract holding that contractual conditions printed on cruise ticket were valid even though they were in small type holding that appellants fourteenth amendment due process claim did not require reversal where they failed to show that they were prejudiced holding that film negatives and master recordings were tangible personal property even though they were valued in part for their intellectual content because they were also physically useful in the manufacturing process