Both parties claimed that the other had infringed upon their patents. The court ruled that sampling without permission infringed copyright. Illumina claimed that Oxford Nanopore infringed on its patents. The court found that Samsung had infringed Apple's patents. Some patents were held to be invalid, while others were infringed by Apple. Fake books originally infringed copyrights, and their circulation was primarily underground. Drinker and Harvard University sued Emerson, claiming he had infringed on patent rights. NEC investigated and sued Epson on the claim that its BIOS infringed their copyright. Steiner sent WordPress a DMCA takedown notice claiming that Hotham's article infringed their copyright. The writer claims Savage's artistic and literary copyright has been infringed by Gervais. The copy does not have to be exact for the patent to be infringed. Courts consider various factors in order to determine whether a trademark was infringed. As with other Aboriginal rights, Aboriginal title can be infringed. In August 2013, Dyson sued Samsung Electronics over claims his company's steering technology was infringed. They claimed the law infringed article 34.