Yasu Sato authored an article published in NBL No.1230. Yasu’s article, “A recent copyright infringement decision by the Tokyo District Court holding that uploading a newspaper article onto intranet has infringed a copyright of a newspaper publishing company” explores how a court determines copyright infringement when an actual infringing material has not been identified as well as how a court calculates the amount of damages when a copyright holder has set out a list of license fees in utilizing newspaper articles.