This legislation, plus court decisions such as "Apple v. Franklin" in 1983 clarified that the Copyright Act gave computer programs the copyright status of literary works. Many companies began to claim that they "licensed" but did not sell their products, in order to avoid the transfer of rights to the end-user via the doctrine of first sale (see "Step-Saver Data Systems, Inc. v. Wyse Technology"). These software license agreements are often labeled as end-user license agreements (EULAs). Another impact of the decision was the rise of the shrink-wrap closed source business model, where before a source code driven software distribution schema dominated.