"The less developed the characters, the less they can be copyrighted; that is the penalty an author must bear for marking them too indistinctly." So wrote Judge Learned Hand in his landmark decision in Nichols v. Universal Pictures Corp. (1930), ruling that the author of Abie's Irish Rose could not make the charge of plagiarism stick against the producers of The Cohens and the Kellys. A mere "idea" (the scare quotes are Judge Hand's) may be borrowed by anyone, along with stock figures, characters "so faintly indicated as to be no more than stage properties" and "low comedy of the most conventional sort."