The Beastie Boys case mentioned briefly is even more complicated than the others, because while they actually paid ECM records a licensing fee to use a three-note sample of jazz musician James Newton soloing on flute, Newton claimed that he was owed money as "composer" of those three notes. It was a case where the courts had to determine just how many notes from a given piece of music you can play before you are playing what would be recognizable as that composition. As the sequence of notes in question had certainly appeared in music before Newton played them in his solo, his claim was struck down. If Newton had won his suit, every jazz musician quoting two bars from a Charlie Parker solo would henceforth owe Charlie Parker's estate royalties (and Charlie Parker's estate would owe for any notes Parker borrowed from his predecessors). In short, it would be madness, and not just for jazz musicians.