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In 2378, Ardon Broht released The Doctor's work Photons Be Free against his wishes, and was ultimately ordered to recall the distributed copies by a Federation arbiter. Broht believed he could release it because The Doctor, as a hologram, had no legal rights under Federation law and would not be allowed to control his work as an author under "Section 7 Gamma of the Twelfth Guarantee." However, thanks to the testimony of Captain Kathryn Janeway, Lieutenant Commander Tuvok, Ensign Harry Kim, and Seven of Nine, the arbiter was at least willing to accord The Doctor the status of "artist." Much to Broht's displeasure, the arbiter ordered all copies of the holonovel recalled. (VOY: "Author, Author")