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In March, the Supreme Court issued its decision in Kirtsaeng v. John Wiley & Sons, 133 S.Ct. 1351 (2013), where it held that the copyright "first sale" doctrine applies to items manufactured and sold abroad by the copyright owner. The decision makes it harder for intellectual property owners to control importation of "grey goods"—items manufactured abroad by the owner or its licensees, and then imported into the United States to take advantage of better pricing here. However, there remain a number of strategies for controlling such importation and resale.

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