What We Talk About When We Talk About Fictional Characters (and Copyright) - Critical Analysis of Law
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What We Talk About When We
Talk About Fictional Characters
(and Copyright)
Steven Wilf
Abstract
What do pictures want? Echoing the famous question posed by art historian W.J.T. Mitch-
ell, this article interrogates that query within the skein of copyright law. The creation of a
fictional character means seeing a possibly singular, inert image as having a past and a fu-
ture, a panoply of emotional responses and, significantly, desires. Fictional characters are
not copyrightable per se. Rather, protection stems from expression of those characters in
copyrightable works. To determine whether fictional characters have reached the threshold
of complexity worthy of copyright, courts inquire how well a character has been delineated.
For nearly a century, copyright has relied upon traditional round character literary analysis
which looks at a character’s distinguishable features from the audience’s point of view.
Recently, flat protagonist criticism examines whether the character serves as a proper ve-
hicle for the author’s story. This article takes another approach—asking what the image is
trying to tell us about its own absences, needs, and emotional lacunae. Beyond establishing
protection, we need to query what protagonists are unworthy of copyright. I argue that
stereotypes should be held to stricter scrutiny as creating insufficiently desiring characters.
“There’s nothing sadder than a puppet without a Ghost.”
Ghost in the Shell
This essay’s title is shamelessly borrowed from Raymond Carver. In the first paragraph of
his story What We Talk about When We Talk about Love, readers are introduced to Mel McGin-
nis, who claims the right to ruminate about romance around the kitchen table with friends
because he is a cardiologist. What makes McGinnis a character with more than a few
rounded touches? Is it his profession, gender, and image, or his fleeting brushes with the
emotional side of the human heart? Fictional characters are not copyrightable per se; rather,
the protection stems from the expression of those characters in copyrightable works.
Anthony J. Smits Professor of Global Commerce, University of Connecticut School of Law. Earlier versions
of this article were presented at the Yale Law School Copyright and Collaboration in the Theater Conference,
organized by Derek Miller and Brent Salter, and the Tel Aviv Law Faculty Workshop on Law and Technology,
organized by Michael Birnhack and Assaf Jacob. My special thanks to Christine Ross who prompted my
interest in Annlee. I appreciate the comments of Marta Figlerowicz, Julia Simon-Kerr, Willajeanne McLean,
Brent Salter, and Simon Stern. Carlos de la Cruz and Luc Saucier generously responded to my queries. The
curators of the Van Abbemuseum in Eindhoven, particularly Margo van de Wiel, were remarkably helpful in
providing materials. I could not have written this article without access to their archives.
ISSN 2291-9732
52 Critical Analysis of Law 7:1 (2020)
Courts therefore must determine whether fictional characters reach the threshold of com-
plexity worthy of copyright.
Characters inhabit storyworlds. And it is impossible to disentangle a fictional per-
sona from its context. Indeed, the United States Copyright Office insists fictional characters
constitute a “mere concept” and are not themselves copyrightable. Instead, the rendition of
a character is protectable within the context of the expression of the work as a whole.1
Other jurisdictions, such as Israel, view imaginary characters as copyrightable in their own
right.2 Yet whichever approach is taken, copyright finds itself in the difficult position of
determining a number of thorny issues: what is a character—must it be envisioned as hu-
manoid, composed of biologic tissue, or, indeed, possessing a personality? Can we construct
a hierarchy of character whereby some protagonists might be more worthy of protection
than others? And does literary analysis provide any assistance in sorting out the way law
winds its way through the murky, boundary-crossing rendering of persona as literature—
and, ultimately, as law?
The United States law of character copyright has been in disorder for nearly seventy
years. Critics describe it as “muddled,” “quixotic” (to borrow a term from a rather famous
protagonist), and “riddled with uncertainty and inconsistency.”3 Courts have been divided
between two major tests deployed to determine whether a fictional character may receive
copyright protection. The Ninth Circuit has relied upon the “Sam Spade Test,” named be-
cause the initial case involved Dashiell Hammett’s protagonist, under which a character is
entitled to copyright protection if “the character really constitutes the story being told”
whereas no protection is afforded “if the character is only the chessman in the game of
telling the story.”4 An alternative analysis, sometimes termed the “especially distinctive” or
“sufficiently delineated” test, created by the Second Circuit, was articulated by Judge
Learned Hand in Nichols v. Universal Pictures Corp.5 According to this opinion, characters,
1 U.S. Copyright Office, Compendium of U.S. Copyright Office Practices § 101 (3d ed. 2014)
(http://www.copyright.gov/comp/comp-index.html). Some commentators have recommended an
amendment of the Copyright Act to include a subject matter category specifically for fictional characters.
David B. Feldman, Finding a Home for Fictional Characters: A Proposed Change in Copyright Protection,
78 Calif. L. Rev. 687 (1990).
2 P.L.A. 2687/92 Geva v. Walt Disney Co., 48(1) P.D. 251 (1993).
3Zahr K. Said, Fixing Copyright in Characters: Literary Perspectives on a Legal Problem, 35 Cardozo L. Rev.
769, 772 (2013); Kathryn M. Foley, Protecting Fictional Characters: Defining the Elusive Trademark-
Copyright Divide, 41 Conn. L. Rev. 921, 926 (2009); Francis M. Nevins, Jr., Copyright + Character =
Catastrophe, 39 J. Copyright Soc’y 303 (1992). For alternative methods of protection, see Kenneth E. Spahn,
The Legal Protection of Fictional Characters, 9 U. Miami Ent. & Sports L. Rev. 331 (1992).
4 Warner Bros. Pictures v. Columbia Broad. Sys., 216 F.2d 945, 950 (9th Cir. 1954). The Ninth Circuit has
recently adopted a three-prong test that aligns it more closely to the Second Circuit’s substantial similarity
standard. To be protected, a character must: (1) have physical as well as conceptual qualities; (2) be sufficiently
delineated; and (3) be especially distinctive. D.C. Comics v. Towle, 802 F.3d 1012, 1021 (9th Cir. 2015), cert.
denied, 136 S. Ct. 1390 (2016). In Rice v. Fox Broad Co., 330 F.3d 1170 (9th Cir. 2003) the court deployed
simultaneously the Sam Spade and Sufficiently Delineated tests.
5 45 F.2d 119, 121 (2d Cir. 1930).
Wilf — What We Talk About 53
much like plot, may “correspond . . . closely enough for infringement” and “the less devel-
oped the characters, the less they can be copyrighted; that is the penalty an author must
bear for marking them too indistinctly.”
Despite a long-standing circuit split, courts agree that a hierarchy exists among lit-
erary characters. Some protagonists are sufficiently complex to warrant protection, others
are so sketchy as to be relegated to a marginal place outside the ambit of copyright. Setting
aside the long-standing copyright doctrine of aesthetic neutrality (abstaining from what Ol-
iver Wendell Holmes, Jr. called “the dangerous undertaking” of discriminating between
different works of art), this has meant favoring certain protagonists rather than others. Why
the focus on distinguishing between characters? Protagonists serve as bridges between orig-
inal works and derivative works such as sequels. They therefore can tell us very quickly if a
work violates copyright’s right of adaptation. Using the same character is prima facie evidence
that a work is simply a derivative extension of the original. Moreover, when secondary users
deploy a character they can change how we consider them in the original work. The use in
a sequel, for example, creates a future for a protagonist that makes us rethink how they
acted in the past. Characters possess an uncanny ability to be genre-crossing—serving as
central elements in such genres as novels, dramatic works, operas, video games, films, com-
ics, and graphic novels. When such characters make the passage from a novel to a motion
picture, readers might never again visualize the original fictional work in quite the same way.
Characters are important for copyright. But two aspects of current copyright doc-
trine operate against our ability to protect only the most worthy characters. First, courts tend
to favor characters with graphic representations whose images are drawn with clear lines
and embody distinct physiognomic traits. Comic book superheroes, for example, have
found particular favor under copyright law.6 Perhaps this is because pictorial images are
easier for showing similarity. It is much more difficult to compare the psychological pos-
tures of a fictional protagonist. Pictorial representations apparently seem less fuzzy to
magistrates than literary figures whose distinctiveness might reside in interiority, dialogue,
and intricate habits of mind. “An image has the power to astonish and make you see the
world through fresh eyes,” writes French novelist Michel Houellebecq, “but only literature
can put you in touch with another human spirit with all its weaknesses and grandeurs, its
limitations and obsessions.”7 And, secondly, courts in a rather careless fashion often identify
more features as supporting copyright protection. Yet why should an author simply heaping
on additional external or inner characteristics—height, hair color, verbal tics, temperament,
odd quirks, and a host of other traits from a menu of possible protagonist attributes—make
a character any stronger? Might not the most compelling fictional characters be elusive?
6 Warner Bros. v. Air Pirates, 581 F.2d 751 (9th Cir. 1978), applying the Sam Spade test, explains the privileging
of comic illustrations: “[W]hile many literary characters may embody little more than an unprotected idea, a
comic book character, which has physical as well as conceptual qualities is more likely to contain some unique
elements of expression.”
7 Michel Houellebecq, Submission 4-5 (Lorin Stein trans., 2016).
54 Critical Analysis of Law 7:1 (2020)
A better case might be made for literary depictions being more worthy of copyright’s
favor than graphic images. Words can draw out a character more effectively than a visual
depiction. The novel is the genre of the backstory, theatrical drama exposes the way a char-
acter interacts with others so that interpersonal exchanges transform the dramatis non-
personae into multidimensional characters. Literary protagonists carry plots on their backs
like a band of hardy Sherpas. But they are also constituted through encounters with anom-
alous situations, the upending of their lives, chimeric psychological postures, a sense of
hybridity—which Homi Bhabha believes creates cultural complexity much as sand prompts
oysters to form pearls, and, above all, by a sense of past.
This essay seeks to pose art critic W.J.T. Mitchell’s seminal query: what do pictures
want? But, instead, it asks: what do fictional characters want—what are their desires, appe-
tites, animating qualities that make them akin to humans even if they are composed of ink
and pulp, words and more words, rather than the usual biological ingredients of blood and
tissue?8 It contends that every character is born in loneliness. Doomed to emerge from the
mind of an author and existing in fixed tangible form separated from their author’s fluid
imagination, protagonists seek to assuage their terrible solitude. Two aspects of a character
provide a means of surmounting the isolation of fixation: first, a backstory with a complex
past—a genealogy, a situating in place and time, and an emerging sense of a personality
constructing by its interactions; and, secondly, the encounter with other characters—what
I call entourage—the dense network of other characters with their own desires and pur-
poses. Often the most compelling characters constitute precarious identities that demand
support from authors and readers.9 Those protagonists who successfully elicit such largesse
are especially worthy of copyright protection.
I hope to draw upon the continuing conversation about the nature of character in
the humanities to construct a more sophisticated way to think about character itself. The
argument is deceptively simple: characters want to be human. Critical to the intervention of
crafting a reinvigorated standard for copyright protection is to determine what precisely it
means to be human: to experience an evolution in perception, to interact with other humans
in such puzzling phenomena as eros and vengeance, to encompass a sufficiently complex
interiority, and, above all, to have a past. In short, a character consists of the desire for a
history and a social network.
This essay consists of two interlocking parts. The first section deploys the manga
character Annlee as a point of departure. After the conclusion of a major collective art
project utilizing Annlee’s graphic image, the artists who owned the copyright returned the
legal rights to the anime figure herself through constructing a trust. This remarkable legal
maneuver might well be the first time a fictional character herself has claimed rights. No
further use of the image would be permitted. What kind of character is Annlee? Near the
8 W.J.T. Mitchell, What Do Pictures Want? The Lives and Loves of Images (2006).
9 Oliver Asselin et al., Precarious Visualities: New Perspectives on Identification in Contemporary Art and
Visual Culture 1-20 (1988). Christine Ross’s excellent introduction underscores the importance of destabilized
identities in the visual arts.
Wilf — What We Talk About 55
beginning of her creation, she was neither sufficiently well-delineated nor the centerpiece
of a story—and therefore incapable of receiving character copyright protection beyond
simply her likeness. How does this modest figure, composed of nothing more than ink and
the untouched gaps between markings, acquire a sense of character? This section of the
essay analyzes Annlee’s close—but ultimately unsatisfying—brush with humanity. It con-
cludes with my probing the boundaries of character development by embarking on a
performative art project of my own, a form of humanities empiricism, where through
graphic art and prose I attempt to infringe Annlee’s copyright in order to test the limits of
Annlee’s claims to protection.
Examining the existing modes of protecting character under copyright, the second
section critiques their underpinnings in literary theory. Copyright protection of fictional
characters was an invention of Judge Learned Hand in a 1930 case, Nichols v. Universal Pic-
tures. Hand’s opinion drew heavily upon the literary analysis of the well-known British
novelist E.M. Forster, published three years earlier in 1927. The Second Circuit’s “suffi-
ciently delineated” test is a legal embodiment of Forster’s argument that characters must be
well-rounded. Forster’s focus on the complexity of character was very much part of a post-
World War I literary world where the most important genre was the novel. Novels often
associated irony with a well-developed persona, considering characters as mansions com-
posed of many rooms. By contrast, the Ninth Circuit’s Sam Spade test, measuring the
significance of a character by whether it is the story being told, is heavily cinematographic.
It sees character as the centerpiece of a narrative much as in a biographic picture or biopic.
Indeed, the Ninth Circuit’s decision, set forth by what Judge Alex Kozinski would later call
the court of the Hollywood Circuit, essentially asked whether the character’s challenges and
the successful overcoming of those challenges constitute a story in itself. The biopic as a
genre was said to have reached its apotheosis in the late 1950s.10
How might a copyright doctrine shaped by contemporary digital reproduction be
different than those coming of age in the halcyon days of the novel or classic studio film?
And do new approaches to literary criticism alter the way we conceive of character? Well-
rounded characters and focal-point characters (for that is how we might summarize the
circuit split) both presume an outsider who is judging the degree to which the fictional char-
acter is important—and making that the yardstick for whether copyright grants protection
to a particular literary cipher. This article will turn that conception on its head. It suggests
that we need to ask: what does this character want? The character might compel through its
neediness, its privation in terms of a backstory, its meager convivial milieu, or its lack of a
winding interior labyrinth. Indeed, the very flatness of the character might be its distinctive
posture in a literary work. Drawing on the important recent literary criticism of Marta
Figlerowicz and the guidance of the anime figure Annlee—who accompanies us through
the netherworld of disadvantaged characters—this article reminds us that even a sad pup-
pet, a shadowy specter, longs for a human soul.
10 George F. Custen, Bio/Pics: How Hollywood Constructed Public History 1-31 (1992).
56 Critical Analysis of Law 7:1 (2020)
I. Mojo in Manga
Annlee was sold at a tender age to a pair of strangers. Pierre Huyghe and Philippe Parreno
bought the rights for an eleven year-old manga character from a commercial Japanese ani-
mation house which specialized in developing images for cartoons, market advertising, and
video games. Her copyright cost a mere $428. There was nothing special about Annlee. In
fact, she looked like someone who could slip into a crowd of anime without eliciting notice.
At the time of her sale, Annlee was an open-eyed, slight, pre-pubescent girl with crinkly
pencil-thin eyebrows and lips [Figure 1]. Peeking out from a mop of faintly blueish hair was
a single elfin pointed ear. Her head is directed downwards, almost as an act of submission.
She is not a sexy anime, a superhero in waiting, or the kind of magical protagonist you
identify with when you want to escape the confines of an all-too-ordinary life. She is not an
astonishingly beautiful anime like the ice maid Yukina whose heart—so unlike her kin—is
filled with love and whose tears instantaneously congeal into pearls. Annlee is simply an-
other waif lost in her manga universe.
Figure 1. Original Purchased.
It was precisely this generic, undistinguished quality that appealed to Huyghe and
Parreno. Given her undifferentiated appearance, Annlee was destined to vanish as a usable
image rather quickly. She certainly would not have survived long in a medieval caricature-
eats-caricature fantasy world where deft swordsmanship and raw courage are necessities.
Huyghe and Parreno sought to appropriate the character, bringing her to life so that she
might be “rescued from extinction.”11 Yet Huyghe had his own artistic agenda. He stated
his goal rather simply: “[W]e wanted to free a character from the fiction market.”12 Accord-
ing to Parreno, “We looked for a character and we found this one. A character without a
name, a two-dimensional image . . . a character without a biography and without qualities,
11Tate Modern, No Ghost Just a Shell Exhibition Description (2006); Deel 2, Van 9, Inv. m. 289 (Van
Abbemuseum Archives).
12 Pierre Huyghe & Philippe Parreno, No Ghost Just a Shell 15 (2003).
Wilf — What We Talk About 57
very cheap, which had that melancholic look, as if were conscious of the fact that its capacity
to survive stories was very limited.”13
Annlee’s generic features were no accident. She was “industrially developed for
merchandising and other commercial purposes [and therefore] can be understood as a sign,
an adorable yet blank signifier—indeed a perfect vehicle for the global circulation of cultural
meanings, whether or not mediated by narrative form.”14 Annlee nonetheless already had
the kernel of a character. She was female—even if Huyghe and Parreno envisioned her as
stripped of gender.15 And there was something of a persona concealed inside of her insofar
as their choice of Annlee was motivated by the perceived “melancholy in the image.”16
Altering the original purchased drawing, Huyghe and Parreno provided Annlee with an
artistic nip and tuck. Her eyes became slanted and stripped of pupils—accentuating her
emptiness, her nose less button-like, and her lips stepped out beyond the thin line of the
original anime figure. Annlee remained recognizable, even if looking a bit more alien [Figure
2].
Figure 2. Richard Phillips Annlee (2002) showing version created
by Huyghe & Parreno holding original image.
The idea was to create a collaborative artistic project around Annlee’s likeness. She
would be rendered in different media by a number of different artists, provided with a
variety of identities, and, ultimately, her copyright would be placed in a trust belonging to
Annlee herself. Annlee would be “liberated from ownership.”17 The Annlee exhibit was
intended as an inquiry into the meaning of artistic authorship—and it entailed the deploy-
ment of legalities as much as paint, putty, various metals, celluloid, and the other materials
13Id. For a political reading of the project, see Marc James Léger, The Ghost Is a Shell, 91 ETC 16 (2010-
2011).
14Jiwon Ahn, Animated Subjects: Globalization, Media, and East Asian Cultural Imaginaries 145-47 (2007)
(unpublished Ph.D. dissertation, University of Southern California).
Huyghe & Parreno, supra note 12, at 16. See Parreno’s contribution to the project, Anywhere Out of the
15
World (2000) (https://www.youtube.com/watch?v=DvS3jKzqYhE).
16 Huyghe & Parreno, supra note 12, at 16.
17Tate Modern, No Ghost Exhibition; Leif Dahlberg, Annlee or Transposition as Artistic Device, in
Transpositions: Aesthetico-Epistemic Operators in Artistic Research 97 (Michael Schwab ed., 2018).
58 Critical Analysis of Law 7:1 (2020)
commonly found in artist studios. Instead of authorship creating a material form that ulti-
mately would be copyrighted, the artistic production would be self-consciously non-
definitive and serve as a catalyst for the next work.18 Eventually, the copyright would belong
to Annlee herself. What is of particular interest here is that law’s abstractions and art’s ab-
stractions are intertwined throughout the fashioning of Annlee. Such conceptual art poses
a salient question for copyright. What might the negative space surrounding Annlee’s image
entailing artistic authority, legal rights, and the relational network of creators tell us about
the nature of character itself?
A. Of Ghosts and Shells
Naming the Annlee exhibit No Ghost, Just a Shell was intended as a gesture towards
the Japanese manga franchise launched in 1989 entitled The Ghost in the Shell about a fictional
counter-cyber-terrorist organization. In its stories, Public Security Section 9, as the organi-
zation is called, searches for a rogue operative called the Puppet Master. The Puppet Master
is a “ghost hacker” capable of infiltrating and seizing control of the cybernetic components
of human beings. He plants in them false memories (“ghosts”). Major Motoko Kusanagi,
the Section 9 member protagonist of the series played by Scarlett Johansson in the 2017
United States film adaptation, chases him as she confronts her own identity as both an
erotically charged woman and a cyborg.19 She is constructed of such a large number of cyber
augmentations that her own humanity is brought into question. Indeed, much of the Japa-
nese series delves into the blurred, jostled complexity of the distinction between man and
machine. Yet figures from the original Japanese franchise like Major Kusanagi have as their
foundation human origins. They are, in this sense, ghosts of a previous self. By contrast,
Annlee was conceived of as simply a shell—a vessel for the ideas, aspirations, and per-
formative desires of those who contribute to her (re)-creation.
Between 1999 and 2002, Huyghe and Parreno embarked on the undertaking of
shaping Annlee’s identity. Asking other artists to join the project, Huyghe and Parreno in-
tended to experiment with how collective creation might contribute to the erasure of
authorship. Annlee was rendered as a static computer image that could be shared as an
open-source freeware character. Huyghe described Annlee as “a sign around which a com-
munity has established itself . . . . Unlike a log, it’s a fragile sign without autonomy; it has
that ability to become plural and complex.”20 Huyghe and Parreno understood romantic
notions of individual authorship as emerging only in the nineteenth century. This
18Hans Ulrich Obrist on the Historic Import of AnnLee, Pierre Huyghe and Philipe Parreno’s Self-Aware
Manga Creation (https://www.artspace.com/magazine/art_101/book_report/no-ghost-just-a-shell-phaidon
-53070).
The United States film is a remake of a 1995 Japanese motion picture by the same name directed by Mamoru
19
Oshii.
20 Huyghe & Parreno, supra note 12, at 17.
Wilf — What We Talk About 59
conception, shared by a generation of copyright scholars, led them to believe that there was
a pre-modern model of collective artistic endeavor.21
The idea was to challenge copyright at the very moment of production. In Parreno’s
words: “Pourquoi le libéralisme a-t-il besoin de cette célébration des auteurs à travers le copyright?”22 They
argued for resurfacing an eighteenth-century artistic tradition where multiple artists worked
on a single canvas.23 Parreno called this an “aesthetic of alliances.”24 Yet their experiment
engendered a fragile alliance at best. The objects produced share little relationship to one
another.25 In fact, the very collective nature of the enterprise might have prevented artists
from imprinting Annlee with a truly human character. Huyghe and Parreno invited a num-
ber of other internationally recognized artists, including François Curlet, Liam Gillick,
Dominique Gonzalez-Foerster, Mehdi Belhaj-Kacem, Melik Olanian, and Rirkrit Tiravan-
ija. It was an international collaboration—which limited the interaction of the artists in the
course of production. Eighteen different artists produced twenty-eight independent
works.26 Their project, entitled “No Ghost Just a Shell,” included a potpourri of artistic
genres—eight animation videos, sculpture, painting, sound, installation works, prints, and
performance art.27
Annlee works were exhibited in nearly twenty-five locations mostly in Europe,
though in the United States and Japan as well—and not always as a united collection of
shared works.28 No attempt was made to bind together the separate works rendered in a
variety of materialities by deploying the copyright doctrine of the compilation—where a
copyright exists in the arrangement as well as individual underlying expression. Indeed, the
collaborating artists were simply furnished with Annlee’s image without any kind of licens-
ing agreement. Copyright law, which has the power to connect disparate works, was
sidelined in the making of the project’s objects. As a result, the idea of the collective re-
mained a cluster of fragmented artistic imaginaries. Huyghe’s videographic work One Million
21There is a vast literature on romantic authorship in copyright. Martha Woodmansee’s “On the Author
Effect: Recovering Collectivity” provides a fine introduction to the subject. The Construction of Authorship:
Textual Appropriation in Law and Literature 1 (Martha Woodmansee & Peter Jaszi eds., 1984).
22Annick Rivoiore, “Produire une idée à partir de l'image”: L’artiste Philippe Parreno explique son travail
autour d’Ann Lee, icône 3D (http://www.liberation.fr/week-end/2001/07/07/produire-une-idee-a-partir-
de-l-image_370920) (“Why does liberalism need this celebration of authorship through copyright?”).
23 Philippe Parreno interview with Andrea K. Scott, Artforum (April 23, 2001), https://web.
archive.org/web/20091005051806/http://www.artforum.com/index.php?pn=interview&id=94.
24 no ghost just a shell (http://www.mmparis.com/noghost.html).
25Alexandra Lucas, Donner vie à un personage imaginaire: Annlee dans No Ghost Just a Shell (1999-2002)—
Projet initié par Pierre Huyghe et Philippe Parreno (master’s thesis, Histoire de l’art, Université de François
Rabelais, 2007).
Netherlands Media Art Institute, Call for New Annlee Art Works: NIMk Wants Your Interpretation of the
26
Annlee Project! (http://www.nimk.nl/eng/call-for-new-annlee-art-works).
27 Chrissie Isles et al., Dreamlands: Immersive Cinema and Art 1905-2016, at 125 (2016).
28Vivian Van Saaze, Installation Art and the Museum: Presentation and Conservation of Changing Artworks
151 (2013).60 Critical Analysis of Law 7:1 (2020)
Kingdoms, for example, portrays Annlee walking through an animated mountainous moon-
scape. The terrain is rocky, pockmarked, and otherwise uninhabited. Annlee herself is an
iridescent blue outline who slowly walks, projecting the sense that she is a forlorn, eerily
spectral figure [Figure 3]. There does not appear to be any direction for her movement.
Even as a rambler Annlee remains merely a shell.29
Figure 3. Pierre Huyghe, One Million Kingdoms
Was Huyghe constructing character in One Million Kingdoms? As one critic suggested,
he drained Annlee of a world as much as he was creating one for her. 30 Huyghe may have
thought of his act as opening Annlee to endless possibilities—as a shell which might be
filled rather than a ghost. Yet he provided her with nothing but ventriloquist words. There
is a mélange of phrases from Neil Armstrong’s pioneering moonwalk and Jules Verne’s
Voyage to the Center of the Earth. Annlee is a voyager, an explorer. Compelled to utter the
scripts of others, she is incapable of fabricating her own language.
Rirkrit Tiravanija’s audiovisual work accentuates Annlee’s ventriloquist objecthood.
Tiravanija depicts Annlee reading the entirety of Philip K. Dick’s canonical speculative fic-
tion novel Do Androids Dream of Electric Sheep? In this tale set in a post-apocalyptic San
Francisco, the central character, Rick Deckard, is a bounty hunter tasked with finding es-
caped Nexus-6 androids. Dick’s novel, later reworked as the Blade Runner films, serves as a
meditation on the line dividing human from android.31 The androids are bioengineered to
be virtually indistinguishable from humans, though sometimes superior in physical prowess
or psychological resilience. These Replicants, using the designation from the film version,
are implanted with memories and therefore are difficult to distinguish from human beings.
Humans have a sense of empathy while Replicants do not. The Voight-Kampff Test meas-
uring empathetic responses is deployed by characters to discriminate between human
bounty hunters, who ironically are capable of empathy, and rogue androids. Yet androids
apparently can develop empathy if they interact with people for over four years. Rachael
Rosen, Dick’s Replicant female protagonist, is programmed to be receptive to the emotions
29 Leif Dahlberg, Transpositions: Aesthetico-Epistemic Operators in Artistic Research 97-115 (2018).
30 Heather Warren-Crow, Girlhood and the Plastic Image (2014).
31 Blade Runner (Amy Coplan & David Davies eds., 2015).Wilf — What We Talk About 61
of others—even to the point of embarking on a romance or establishing trust. What does
it mean for Annlee to read her story? Does she identify with Rosen—unlike we humans,
who view Deckard as the lead character? Might Annlee have had an opportunity to develop
her own emotional compass if only she had been given an opportunity of intermingling
with people for just a bit longer? Or, even better, if she could have been fashioned by only
a single creator rather than a miscellany of different artists?
Melik Ohanian’s Annlee depicted a figure in a deep reverie with a musical back-
ground: “The passage of time is floating dimly away/I can’t see the lines I used to think I could read
between/Perhaps my brains have turned to sand.” There is a dream—but no content to the dream.
Androids may dream of electric sheep, but we have no idea what fantasies or imaginary
worlds might beckon to Annlee late at night. Joe Scanlon’s contribution, Do It Yourself Dead
on Arrival, is equally elusive. It depicts a coffin flanked on either side by dried flowers in
vases.32 Tacked on the wall are pages of a do-it-yourself manual and a copy of the legal
document assigning her rights to a foundation upon her death. Does this suggest that
Annlee’s fragile existence is near an end? Has she constructed the terms of her own last
rites by constituting such a transitory figure in the first place?
Skin of Light, conceived by the French actress Catherine Deneuve and executed by
Huyghe and Parreno, depicts a face that is illuminated due to her fame yet looks ill at ease,
perhaps martyred by always appearing in the limelight.33 The works were so disparate and
in so many different media that the artists used a glistening white, rather bulky robot to
unify the exhibit space, and—at the same time—show two films. It followed the lines of
the carpet as it moved amid surrounding exhibits.34 The robot has ceased to function. Like
the rest of the art pieces, it was consigned to a storage facility at the conclusion of the
exhibition.
Figure 4. Image from Exhibition Catalog Shell
If the various exhibitions of Annlee failed to create unity, there is a bit more
32 Joe Scanlan, Do It Yourself Dead on Arrival, Van AbbeMuseum (2002) (https://vanabbemuseum.
nl/details/collectie/?lookup%5B41%5D%5Bfilter%5D%5B0%5D=id%3AC3055).
33 Marcia Tanner, No Ghost Just a Shell, Stretcher (http://www.stretcher.org/features/no_ghost_just_a_shell/).
34 Pierre Huyghe et al., Travelling Pod, MediaBank (2003) (https://mediabank.vanabbemuseum.nl/857).62 Critical Analysis of Law 7:1 (2020)
connection provided within the compass of the retrospective catalog, No Ghost Just a Shell,
which Huyghe and Parreno edited [Figure 4]. They wrote a poem as the introduction to
their book, an anthology of works directed towards Annlee’s image. The poem is supposed
to be composed in Annlee’s own voice. It reminds us of the thinness of her past, and,
indeed, the slender material upon which her character is made—simply a sketchy image and
a name. Like so many parts of Huyghe and Parreno’s project, it is an act of ventriloquism.
The first-person poem begins:
My name is Annlee! Annlee!
You can spell it however you want!
I was bought for 46000 Yen
...
Some other characters had the . . .
Some other characters had the possibility of becoming a hero.
They had a long psychological description, a person history,
Material to produce a narration.
They were really expensive when I was cheap!
Designed to join any kind of story,
But with no chance to survive any of them.
I / was never designed to survive . . .
...
I / am / a product
a product freed from the market place I was supposed to fill.
Drop dead in a comic book.
I will never forget.
I had just a name and an ID.
My name is Annlee!
My name is Annlee!
...
I am an imaginary character.
I am no ghost, just a shell.35
The various, largely disparate artistic renditions of Annlee failed to provide a personal back-
story. As a visual object, she remained stripped of an interior labyrinth. Annlee was generally
portrayed as a solitary figure divorced from any sort of social milieu. She was a projection
of artists. Ironically, however, all these absences accentuated her melancholic image—the
sense that Annlee’s psychic needs remained unmet. What does a character want? How
might we fill the void? Although Huyghe and Parreno conspired to keep her merely a shell,
the shift to the first-person voice suggests that Annlee was making the difficult, deeply
human transition to becoming a fictional character.
35 Huyghe & Parreno, supra note 12, at 33-35.Wilf — What We Talk About 63
One contributor to the Huyghe and Parreno volume on Annlee created a series of
case notes as if a psychoanalyst had coaxed Annlee to his therapeutic couch. “She cannot
be just a shell”— he mused—“shells fill up.”36 This reminded the analyst of a recent voyage
he took to Kitakyshu, Japan—where he attended a symposium on what makes us human:
“The truth of the matter was there was no way you could separate Annlee from humans
because there was no way she could mean something to any chimp, ape, mouse, rabbit, or
paramecium. There was something human about her because only humans were interested
in her.”37 But this supposed inner articulation quickly circled back to artists and viewers.
Huyghe depicted Annlee among hollow craters because she—like them—represented a to-
pography of the void. “There is something about Annlee that we all relate to—this empty
feeling, waiting for someone to fill you in, waiting for something to happen. Dr. ATP had
seen it numerous times in his clinic. Annlee has become a visible symptom. Somebody drew
her to rid himself of feelings of emptiness and despair, but her image remained and the
image has now become part of the public landscape.”38
But did Huyghe, Parreno, the artists who enrolled in the project, and even the critics
who would come later work to fill that emptiness? Israeli author David Grossman describes
his relationship to his characters as one of provider. In his essay, The Desire to Be Gisella, he
recounts how he was puzzled during a reading of one of his novels that an uncle of Gisella,
a character in Grossman’s novel See Under: Love, had installed an extra pedal for her sewing
machine. He could not recall why he had added that detail until he consulted the novel and
realized he had made her legs too short to reach the existing pedals. As Grossman pointed
out, when he invents a character he wants “to know and feel and experience as many char-
acteristics and psychic arrays as possible, including things that are difficult even to name.
For example, the character’s muscle tone, both physical and emotional: the measure of vi-
tality and alertness and tautness of his or her physical and emotional being. The speed of
her thought, the rhythm of his speech, the duration of pauses between her words when she
speaks. The roughness of his skin, the touch of her hair. His favorite position, in sex and
in sleep.”39
Grossman’s familiar relationship with character, his intimate canniness, leads to
fashioning the small details that form a character’s complex composite portrait. Like many
authors, he provides vivid details of physiognomy, material objects—considering the psy-
chological as well as the physical needs of his characters. Yet for all the many collaborators
on the Annlee project we never have a sense of an evolving figure who has assumed an
identity. Huyghe called Annlee an imaginary character who “while waiting to be dropped
36Israel Rosenfeld, Dr. Arnold T.P. West’s Thoughts on the Annlee Case, in Huyghe & Parreno, supra note
12, at 97-100.
37 Id. at 99.
38 Id. at 99-100.
39 David Grossman, The Desire to Be Gisella, in Writing in the Dark: Essays on Literature and Politics 42
(Jessica Cohen trans., 2008).64 Critical Analysis of Law 7:1 (2020)
into a story, a theoretical life, was diverted from fictional existence.”40 Why could not
Annlee find her way back to such a fictional actuality? As portrayed by Huyghe and
Parreno’s collective, Annlee had no meaningful relationships, no backstory, no deeply
crafted interiority, and no articulated intimate grammar of needs. As a graphic representa-
tion, as a series of curved lines, she might be protectable under copyright. But not as a
literary protagonist. Beyond the line boundaries of her image, Annlee never becomes a
character.
To a large extent, Annlee’s fate was sealed at the very moment she was purchased.
Huyghe and Parreno’s story is a rescue narrative. Annlee appears as a damsel in distress, as
sleeping beauty, as Pygmalion’s ivory statue waiting to be brought to life. Such a narrative
follows a rigid gender stereotype. The female is passive and her male rescuer is empowered.
There is so much about the Huyghe and Parreno project that is misogynist and patriarchal,
Eurocentric and neo-colonial—this was, after all, a Japanese, though Western-looking, im-
age that was extracted. And significantly they exploited the depiction of a child. Artist Pedro
Vélez, who as we shall see below created a social network profile for Annlee, had her write:
“Once abducted by pimp master Pierre Huyghe and introduced into the world of Gang
Bang . . . is a miracle I’m well and A-OK in Puerto Rico.”41 Huyghe and Parreno were not
the only artists with a rescue fantasy.
B. The Legal Making of a Shell
During the late 1990s, Huyghe increasingly turned his attention to the intersection be-
tween copyright and art. In 1996, a collaboration with Philippe Parreno and photographer
Anna Sanders yielded a series of photographs where there is no picture of a fictional char-
acter. She only exists in bits and pieces through selected texts and illustrations—a “liaison”
of scattered expression.42 These same artists produced a film, Blanche-Neige Lucie (1997) de-
picting the struggle of vocalist Lucie Dolène, the melodic voice of Disney’s Snow White,
for legal control of her contribution to the motion picture.43 Dubbing in French is doublage—
and certainly the relationship between the animated princess and the voice is one of inter-
twining personae. Huyghe had an intriguing approach to Dolène’s legal claim for attribution
and royalties. She had shared her voice with an imaginary character, and the character had
failed to keep its promised (was Dolène double-crossed?). Yet in the end, Dolène won her
lawsuit and like Snow White herself she was brought back to life.44 A second Huyghe film,
The Third Memory (2000), sought to sort out the complex relationship between the real John
40Pierre Huyghe, Two Minutes Out of Time, Purple Diary (2000) (http://purple.fr/television/extract-from-
two-minutes-out-of-time-2000/).
41 Warren-Crow, supra note 30, at 81.
42 Emma Lavigne et al., Pierre Huyghe: A Catalog 48-49 (2014).
43 Amelia Barikin, Parallel Presents: The Art of Pierre Huyghe 99-106 (2012).
44 Id. at 230 n.10.Wilf — What We Talk About 65
Wojtowicz, a New York City bank robber, and the way he was portrayed by Al Pacino in
the Sidney Lumet movie Dog Day Afternoon (1975).45
At Huyghe and Parreno’s direction, Luc Saucier, a Paris lawyer, created a trust for
Annlee’s image. This association was empowered to take all the measures necessary to en-
force legal rights in the representation of her form.46 The artists renounced their own
intellectual property rights in Annlee and granted full title to a trust in her name for consid-
eration of one Euro.47 Only Huyghe and Parreno were identified as potential signatories for
this assignment of rights—and none of the other artists seemed to have been party to the
agreement. It identified as the objective of the trust that Annlee’s image will never again
appear (“l’image d’ANNLEE ne réapparaisse jamais”). According to the legal instrument cre-
ating the trust, “l’acquisition d’ANNLEE s’inscrit dans un projet poétique consistant à affranchir un
personage de fiction du royaume de la représentation” (the acquisition of Annlee comports with a
poetic plan intended to liberate a fictional character from the realm of representation). But
there was a proprietary thrust to the trust. One of the trust’s explicitly stated purposes was
to prevent Annlee from falling into the public domain.48
Yet is that what a character most desires—not to be assigned ownership of her
image in order to exert control over the use of her image, but to be exiled completely from
the realm of representation? The creation of the trust entailed numerous contradictions. If
the figure of Annlee is removed from circulation, are not the artists themselves the benefi-
ciaries of closing off Annlee from others? And what would happen to the material objects
created by the collective project—would they be scattered and commodified within the
domain of art galleries? The Van Abbemuseum in the Netherlands took the highly unusual
step of purchasing an entire collective exhibition. According to the terms of the contract,
the museum guaranteed “the end of the visual exploitation of a sign . . . . Annlee is with-
drawing from the realm of representation and that’s what the museum inherits.”49 But the
ambiguities of possession surely apply to real property claims as well as intellectual property.
Organizing an assemblage of artists turned Huyghe and Parreno into collectors. It was from
their legal status as owners of the tangible objects that they imposed conditions on Annlee’s
use. Parreno explained their strategy of making the character itself rights-bearing: “[W]e’re
trying to give rights to a thing, whereas copyright was invented to protect people’s inter-
ests.” And since the ultimate owner was the Van Abbemuseum, which could exhibit the
45Pierre Huyghe, The Third Memory, Guggenheim.org (2000) (https://www.guggenheim.org/artwork/
10460).
46 Déclaration de constitution d’une association, undated, Van Abbemuseum Archives, Deel 9, van 9 (“. . .
toutes les mesures necessaires a la mise en oeuvre de l ‘interdiction de l'utilisation de l'image d'ANNLEE.”).
47 Id.
48 In an exhibition at the Tate Modern (2006), Huyghe created a series of seven neon signs underscoring his
lack of copyright ownership suggesting his lack of possession over the film Modern Times and John Cage’s
4’33”.
49Huyghe & Parreno, supra note 12, at 23. A second copy was purchased as part of the Miami Rosa and
Carlos de la Cruz collection.66 Critical Analysis of Law 7:1 (2020)
artworks whenever desired, it could hardly be said that Annlee received control of her im-
age. “The history of author’s rights moves from the king to the printer to the publisher,
Huyghe argued, then from the publisher to the author.”50 But what if the ultimate rights
holder in a capital-intoxicated art world is simply the owner who proscribes a work from
freely circulating?
It is not as if Huyghe and Parreno had an antinomian reluctance to deploy law.
According to an agreement between the artists and the Van Abbemuseum, for example, the
robot cannot be used outside the exhibit in the future.51 Indeed, the various museums ex-
hibiting the Not a Ghost, Just a Shell project deployed law as a technology for asserting
property rights. Art collector Carlos de la Cruz purchased the entire Annlee exhibition. His
donation allowing the transatlantic joint ownership of these works by the North Miami
Museum of Contemporary Art (MoCA) and London’s Tate Modern inevitably required a
complicated legal framework to secure the title for both parties.52 Paddy Johnson pointed
out the paradoxes of possession in an article entitled “Calling London! Free Ann Lee from
the Tate!” If the point of the project, he asks, is proposing “scenarios that liberate the manga
character Ann Lee from ownership, why is the Tate holding her reproduction rights hos-
tage?”53 Johnson snapped a photograph at the Tate, prompting the intervention of a
museum guard—to whom he responded, “But I’m freeing Ann Lee from her existence as
a commodity.”
Annlee’s plasticity is not simply an artifact emerging from an artistic gesture. She
shared characteristics with other plastic, ill-defined images that inhabit our digital age. Mash-
up, digital morphing, and the reconfiguration of persona as a changing array of avatars
might be seen as reinvention. But they also reflect a malleability where character might be
imposed from the outside. In our times, DarkFic and Fix-Fic destabilize character through
painting a protagonist with an ever-more-noir hue or rescuing one from an awkward ending.
Yet earlier generations also did not see character as fixed. From Pygmalion to the beautiful
yet vulnerable ingénue, plasticity has been a classic role imposed by men upon young
women. Is Annlee’s image circulating among largely male artists any different? Such images
can be “sculpted like clay and circulated like money.”54 Girlhood is a period defying fixity—
transformative, mutable, and vulnerable. It also is a time of searching: identifying parentage
(if this remains a mystery) and differentiating oneself in distinctive ways. Why deny Annlee
the opportunity to search for a selfhood beyond commodity? How can one be an anime
figure without a quest?
50Rachael M. Wolff, We Bought a Virgin: The Issue of the Artist in No Ghost, Just a Shell, 4 Shift: Graduate J.
Visual & Material Culture 6 (2011). For a particularly notable critique of the art market, see its literary depiction
in Hannah Rothschild, The Improbability of Love (2016).
51Letter 07/10/2003 Agreement of the Van AbbeMuseum and Huyghe and Parreno, Van AbbeMuseum
Archives.
52 Noah Horowitz, Art and the Deal: Contemporary Art in A Global Financial Market 318 n.55 (2014).
53 Paddy Johnson, Calling London! Free Ann Lee from the Tate!, Art Fag City, Oct. 12, 2009.
54 Warren-Crow, supra note 30, at 2.Wilf — What We Talk About 67
Huyghe and Parreno instructed their fellow artists on the Annlee project to “work
with her, in a real story, translate her capabilities into psychological traits, lend her a char-
acter, a text, a denunciation, and address to the Court a trial in her defense. Do all that you
can so that this character lives different stories and experiences so that she can act as a sign,
as a live logo.”55 Annlee was an anime open-source. Yet it was precisely these projects’
vertiginous, incoherent variations that transformed her into a shell simply filled with the
stories of others—none of her own. If the core of character is seeking to be human, then
Annlee found herself pulled in the other direction. Huyghe and Parreno altered her graphic
image prior to circulation among the project’s artists. They took away her large, plaintive,
even slightly moist eyes and replaced them with almond-shaped blank eyes without pupils.
Her skin was smoothed. Annlee looks more cyborg than human. This re-rendering had
philosophical implications as an animation that de-animates—taking the image further
afield from its humanity.
C. Death and the Maiden Revived
Annlee passed away rather dramatically at the December 2002 Art Basel Miami
Beach festival. During its inaugural night, Huyghe and Parreno presented A Smile Without a
Cat: A Celebration of Annlee’s Vanishing. Art patrons gathered on the beach to watch Annlee’s
silhouette shimmering overhead in the midst of fireworks, and then slowly vanishing [Fig-
ure 5].56 It was a Cheshire cat moment. The Lewis Carroll touch was not lost on Huyghe
and Parreno who titled this final Annlee artwork A Smile Without A Cat. “This will be her
last manifestation as her silhouette sparkles and dissipates in a series of fireworks over the
skies of Miami Beach as she is finally disappearing from the kingdom of representation.”57
While the spectacle was quite dramatic—one reviewer called it a “requiem for a mail order
bride”—the funeral was fairly modest.58 She was interred in an IKEA coffin, which may
seem fitting for a graphic image described as unremarkable and generic.59 Huyghe and
Parreno considered Annlee’s end as liberating her from representation. Their lawyer, Luc
Saucier, confirmed that the only way to unfetter Annlee was for the artists to divest them-
selves of the copyright and to bar future use.60 The real end of Annlee was the transfer of
her legal rights to a trust “ensur[ing] that the image of Annlee will never again appear
55SFMOMA Presents No Ghost Just A Shell (https://www.sfmoma.org/press/release/sfmoma-presents-no-
ghost-just-a-shell-annlee-virt/).
56Philippe Parreno & Pierre Huyghe: A Smile Without a Cat (4 works), 2002 (https://www.artnet.com
/auctions/artists/philippe-parreno-and-pierre-huyghe/a-smile-without-a-cat-4-works).
57A Fireworks Project by Pierre Huyghe and Philippe Parreno, A Smile Without a Cat (Celebration of
Annlee’s Vanishing) (http://www.transmag.org/nuevo_transmag/nuevodiseno/projects/presentacion.php?
project=&codigolista=34)
58 Tanner, supra note 33.
59 Id.
60 Valeria Costa-Kostritsky, Délits d’initiés (https://www.vice.com/fr/article/avb7e8/luc-saucier-594-
v4n12).68 Critical Analysis of Law 7:1 (2020)
beyond the existing representations.”61
Figure 5. Death of Annlee Miami Beach Art Basel 2002
Animating an anime character draws upon the philosophical tradition of vitalism.62
But what happens when you take away her life? A number of artists called the killing of
Annlee an intentional homicide—and her mode of burial a disgrace. Artist Pedro Vélez
created a piece of protest art: “Ann Lee Lives!” [Figure 6]. Scrawled on a poster with a very
real-looking photograph of a young woman with shoulder length hair and a welcoming
smile was the statement “You Can’t Kill Ann Lee. She is alive and well in Puerto Rico. Go
Fuck Yourselves.”63 Vélez also established a profile for Annlee on the social media platform
Myspace depicting her as a twenty-three year old female in Puerto Rico. Yet Myspace has
undergone its own death spiral, and no one seems to have logged into Annlee’s profile and
networked with her since 2006.64 As renowned cell-death scientist Claude Ameisen in con-
versation with Pierre Huyghe remarked: “[I]t’s very hard to die when one is not alive.”65
61 Warren-Crow, supra note 30, at 79.
62For the resurfacing of vitalism in modern French thought, see Maurizio Lazzarato, Puissance de l’Invention:
La Psychologie économique de Gabriel Tarde contre le économie politique (2002).
63 Google search: pedro velez ann lee lives (https://tinyurl.com/wu7l8hr).
64 Ann Lee Lives! (http://archive.rhizome.org/anthology/hellinlambuc/www.myspace.com/annleelives).
65 Amelia Barikin, Parallel Presents: The Art of Pierre Huyghe 242 (2015).Wilf — What We Talk About 69
Figure 6. Posthumous Annlee, Pedro Velez
In 2012, a decade after her untimely death, The Netherlands Media Art Institute
invited artists to contribute to a new Annlee exhibit entitled Yes, We’re Open. According to
what the organizers termed an “unofficial” call for art works, “The [Annlee] project was
finalized . . . with the artists definitively killing her off (including a coffin) and liberating her
from the realm of representation—as they described it—by signing over the copyrights of
the image to Annlee herself. Is this really the end? Is Annlee dead, truly free, or both?”66
Presumably without asking Annlee’s own authorization, her legal status was a usable image
to be resurrected. The Media Art Institute provided two rationales which speak to intellec-
tual property debates. First, “copyright was used explicitly to lock up an appropriated image
that has the potential to flow as freely as an open art work.” And secondly, “Annlee has
disappeared as an image, but not as an entity that can be discussed and talked about, or as
a subject for new artworks.”67 In other words, art should be unconstrained by copyright—
and if there are legal consequences, then we might consider classic fair use arguments about
new Annlee art representations a species of comment and criticism addressing the original
Annlee project.
Perhaps this is the approach taken by Romanian-born artist Mircea Cantor. Her
2004 spray paint contribution to the Netherlands exhibit (I 6M STIL7 ALIV3) shows a
red-painted Annlee with the stenciled words “I am still alive” written beneath her upper
torso [Figure 7]. Ironically, the Philadelphia Museum of Art, which currently owns the art
piece, has posted on its website a copy with a legal notice superimposed: “A larger image is
unavailable for this object due to copyright, trademark, or related rights.”68 Artist Tino
Sehgal at the 2011 Manchester International Festival had an eleven-year-old girl circulate
among the audience playing Annlee.69 Was Annlee truly miraculously resurrected like
66 Netherlands Media Art Institute, supra note 26.
67 Id.
68Mircea Cantor, 6M STIL7 ALIV3 (http://www.philamuseum.org/collections/permanent/300108.html
?mulR=25137880%7C2)
69 Tino Seghal Reanimates Manga Character at Frieze, Phaidon (http://www.phaidon.com/agenda/art
/articles/2013/may/08/tino-sehgal-reanimates-manga-character-at-frieze/); David Searle, Through the Trap
Door: Tino Sehgal’s Mesmerising Mind Maze, Guardian, Nov. 16, 2016 (https://www.theguardian.com/
artanddesign/2016/nov/16/tino-sehgal-carte-blanche-mind-bending-exhibition-palais-de-tokyo-paris).You can also read
