There have been multiple attempts to argue that certain versions of Mickey Mouse are in fact in the public domain. In the 1980s, archivist George S. Brown attempted to recreate and sell cels from the 1933 short "The Mad Doctor", on the theory that they were in the public domain because Disney had failed to renew the copyright as required by current law. However, Disney successfully sued Brown to prevent such sale, arguing that the lapse in copyright for "The Mad Doctor" did not put Mickey Mouse in the public domain because of the copyright in the earlier films. Brown attempted to appeal, noting imperfections in the earlier copyright claims, but the court dismissed his argument as untimely.