Franken is the author of four books that made "The New York Times" Best Seller list. His 1996 book "Rush Limbaugh Is a Big Fat Idiot and Other Observations" topped the "New York Times" list; the audiobook, which was read by Franken, won a Grammy Award. In 2003 Penguin Books published his "", a satirical book on American politics and conservatism. The book's title incorporated the Fox News slogan "Fair and Balanced", and had a cover photo of Fox News commentator Bill O'Reilly; that August, Fox News sued claiming infringement of its registered trademark phrase. A federal judge found the lawsuit "wholly without merit." The incident focused media attention on Franken's book and, according to him, greatly increased its sales. The publicity resulting from the lawsuit propelled Franken's yet-to-be-released book to number 1 on Amazon.com.