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This article focuses on the first sale doctrine by way of cases that have gone to the Second Circuit, Ninth Circuit, and the Supreme Court, and reviews the recent Supreme Court decision in the Kirtsaeng v. Wiley case. An analysis of the appropriate literature is carried out, paying close attention to sources that contribute to the library community's opinion on the importance of the first sale doctrine for libraries. The literature review found evidence of similar views on the part of librarians and law professionals of the term �lawfully made under this title� (17 U.S.C. § 109(a)) as meaning works made by the copyright holder, as opposed to a pirated or copy of a work manufactured in the United States. An overview of the opinions of law and library professionals on the issue of first sale and how it contributes to the basic operation of libraries is provided. The intention is to review the ambiguous past of the first sale doctrine and arrive at a clearer understanding of why the Supreme Court has ruled that first sale applies to all U.S. copyrighted works regardless of geographic location of manufacturing.
