When expressing an idea or creating content, creators consciously and subconsciously reference artistic works and concepts that they’re familiar with due to our unavoidable encounters with creative content. Literary works run rampant with references to their predecessors, many classical artists were trained by mimicking their master’s work, political speeches often quote influential figures, and musicians often sample other popular songs. Free speech and expression in the modern era is innately referential. However, as of Oct. 2022, this referential nature is being put on trial in the case of Warhol v. Goldsmith;