 Thus, in the Sixth Circuit, defendants who digitally sampled may not rely on the "de minimis" doctrine to say that they copied such a small amount that they are not liable for copyright infringement.However, they may still argue that their use of the sample is a "fair use"—that is, that the use is transformative, for noncommercial purpose, copied only a small amount, the original had a thin copyright, or the copying did not harm the market for the original work or its derivatives.New York University musicologist and sampling expert Lawrence Ferrara describes the effects of the Bridgeport case on sample-based music as, "extremely chilling, because it basically says that whatever you sample has to be licensed, in its most extreme interpretation."