"Simply according artistic works the same protection as
nonartistic works may not be sufficient to protect creativity.
After all, the very essence of artistic expression is invention
and artists necessarily draw on their own experience.
But if the rules of liability are unclear, artists will not be able
to know how much disguise is sufficient to protect their claims
from the claims of those who may see themselves in the portrayals."
“The Creative Process and Libel,” New York Times Magazine, 5 April 1987