In this New York Times article, Fred Bernstein comments on previous cases involving architecture and copyright, most notably the Shine v. Childs case dealing with the Olympic Tower and the Freedom Tower, and their implications for the present. He brings up an example of early copying in architecture by referring to Thomas Jefferson's University of Virginia, and how it mimics a Neo-Roman style in America. The first United States copyright act was passed in 1790, and copyright legislation in the United States did not involve architecture until 200 years later in 1990. Just as in other areas such as publication and music composition, it is sometimes extremely difficult to discern what parts of a creative work are similar to other works because of deliberate copying or mere coincidence. Although there are numerous obstacles in situations involving imitation in architecture, some architects see imitation or resemblance to their own work as forms of flattery. Architect Daniel Libeskind has presented two points of view on imitation. He doesn't mind that Donald Bates, creater of Federation Square (a large, commercial development in Melbourne, Australia), used acute angles similar to those used in his own work. However, Libeskind has objected to Peter Eisenman's design for the Holocaust Memorial in Berlin, because it looked too similar to a memorial garden he had designed for the Jewish Museum in Berlin. However, the previous two examples deal more with intellectual debate than with copyright law. Copyright is only able to cover "tangible expression", not ideas, which is a clash that is often encountered with copyright issues in architecture. One of the major points of this article is that issues involving plagiarism in architecture rarely make it to court, because architecture is a largely collaborative effort. There is too much activity, combined from project architects, students, project designers, and consultants, for specific copyright cases to be honed out. Bernstein mentions three current cases involving architectural similarities, including one dealing witha partition in a first-class lounge in Kennedy Airport. Mr. Sharples, a partner at the firm SHoP/Sharples Holden Pasquarelli accused architect Zaha Hadid of copying the screen in the airport lounge from one of his firm's designs. This is an example of how copyright cases can sometimes bring out absurdity in issues, especcially in architectural issues in which it is extremely difficult to discern between outright imitation and coincidental similarity.