It also marked the first time that copyright had been vested primarily in the author, rather than the publisher, and also the first time that the injurious treatment of authors by publishers was recognised; regardless of what authors signed away, the second 14-year term of copyright would automatically return to them. Even in the 21st century, the Statute of Anne is "frequently invoked by modern judges and academics as embodying the utilitarian underpinnings of copyright law". In "IceTV v Nine Network", for example, the High Court of Australia noted that the title of the Statute "echoed explicitly the emphasis on the practical or utilitarian importance that certain seventeenth-century philosophers attached to knowledge and its encouragement in the scheme of human progress". Despite "widely recognised flaws", the Act became a model copyright statute, both within the United Kingdom and internationally. Christophe Geiger notes that it is "a difficult, almost impossible task" to analyse the relationship between the Statute of Anne and early French copyright law, both because it is difficult to make a direct connection, and because the ongoing debate over both has led to radically different interpretations of each nation's law.