In 2007 two UC Davis Law School professors argued in the "California Law Review" that "Mary Sue" fan fiction "that challenge the orthodoxy of the original likely constitute fair use". Citing "Campbell v. Acuff-Rose Music, Inc."—which established that commercial parody can qualify as fair use if it can be perceived as commenting or criticizing on the original—and the subsequent "Suntrust v. Houghton Mifflin", the authors wrote that "Similarly, many Mary Sues comment on or criticize the original, while at the same time create something new ... Mary Sues can be commercial and still be fair."