Following the creation of “Paul’s Boutique,” sampled musicians began to more regularly seek paydays for use of their music, sometimes suing to receive their fees. As Kembrew McLeod and Peter DiCola cite in their book Creative License, rap musicians quickly became alert to litigious artists. Posdnuos of the rap group De La Soul recalls avoiding George Clinton music while he was pursuing Westbound Records for sampling-related damages and George Harrison because of his distaste for rap. By the 1990s, it was also becoming clearer that rap was not a passing fad. Rap music was a lucrative business with opportunities for copyright holders to earn money off the music they owned by allowing others to sample it. Costs quickly escalated for the transaction, the negotiations, and the music. Even with all this effort, there was no guarantee that the copyright holder would even allow the sample to be used. Today, artists like Girl Talk who use samples without permission dodge these issues by relying on fair use arguments, a copyright doctrine that allows for use of copyrighted works without permission or payment in limited circumstances. This position is tenuous at best, relying on untested legal theories and alternative distribution channels. This state of affairs would rapidly ensure Yauch’s goal, that an album like “Paul’s Boutique” would never be created again though mainstream distribution. McLeod and DiCola estimate that if “Paul’s Boutique” were to be cleared for all its licenses today, the album would have lost around $20 million.