Secondary liability in copyright has come about with case-by-case decisions. In other words, there has not been any real or consolidated theory. Furthermore, patent and copyright cases have tended to cross-cite each other. Examples of this are cases such as "Kalem Co. v. Harper Brothers" (the producer of the movie Ben Hur (1907 film) didn't himself infringe, but was responsible for making and commercially distributing the infringing film), "Shapiro, Bernstein and Co. v. H.L. Green Co." (a booth in a department store that sold infringing sound recordings and the store was ultimately held liable), and the so-called "dance hall" cases (the operator of an entertainment establishment was held liable because he had effective control of the premises "and" obtained a direct financial benefit derived from charging entrance fees to the public).