 Then, in 1831, the judges of the Court of King's Bench held that his conduct had been unlawful at common law, though not a breach of the Prints Copyright Act 1777.An entrepreneur who sought out other new markets, Heath was a driving force behind, and contributor to, the new genre of the literary annual.He established his own annual, "The Keepsake", first published at the end of 1827, and approached William Harrison Ainsworth to become its editor.