The Ethics of Cultural Appropriation of Identity in Fiction: A Writer's Choices in Cross-Cultural Writing

Stephen J. Quigley | March/April 2011

Stephen J. Quigley


Complete cultural appropriation of identity occurs when the author uses a culturally heterogeneous character with a first-person point of view. In this instance there is the least amount of psychic distance between the reader and the main character.

I. Preface

My wife and I moved to the poverty and red dust of Phnom Penh, Cambodia in 2002 to teach at an affluent international school. At the end of our first year in Cambodia, I enrolled in an MFA program in creative writing and began my studies of cross-cultural writing while simultaneously beginning work on a cross-cultural novel entitled Barrang. The novel concerns the trials of an American embassy family that moves to Cambodia shortly before the 1997 Coup d'etat. Through this writing process, I quickly realized that if I wanted to tell the story with proper balance and perspective, with insight into Cambodia, I needed a Cambodian point of view character. At that time, the idea of writing using the point of view of a Cambodian terrified me, as reflected in early drafts of my novel where the narration is mostly in a third-person objective point of view, more akin to an article in National Geographic than a novel with any insight. But through my own immersion in the Cambodian culture, my point of view moved closer towards my Cambodian character, thus closing the psychic distance; however, due to the fact that I am not Cambodian, I felt like a close third person was as near as I should ethically come to the Cambodian psyche. But in reading Robert Olen Butler's Good Scent from a Strange Mountain for the first time, I believed that if a white guy from Louisiana could write in the first-person point of view of a Vietnamese immigrant living in the United States, then maybe I could do the same with my Cambodian character. But further reflection on my characters, Butler's work, and many other cross-cultural novels, got me thinking not about how I should proceed, but whether or not I should proceed.


II. A Brief Discussion of Appropriation in Relation to the Psychic Distance and Point of View

The point of view of a piece of cross-cultural writing defines its level of cultural appropriation.

There are many cross-cultural stories in which an author uses a culturally homogeneous point of view character to interpret cross-cultural experiences in either first or third person (Going after Cacciato, The Sheltering Sky, The Quiet American), and while in these cases there is cultural appropriation, there is no direct appropriation of cultural identity because the voices of the point of view character and the narrator are of the same culture.

In contrast, when an author uses a point of view character that is culturally heterogeneous in a third-person omniscient work, the author is in fact appropriating the cultural voice of the point of view character. In this case, relative appropriation of identity occurs, for both the narrator and the character are evoked. Many writers feel a degree of protection from cultural appropriation of identity in this mode of writing because of the very fact that this mode blends both the narrator's voice and the main character's perspective in the telling of a story. This point of view allows the author to pick and choose scenes as stated, but more importantly, to control the psychic distance, that is, how closely the author wants to bring the reader into the thoughts and feelings of the central point of view character. In third person, using a culturally heterogeneous character, the closer a writer moves from the objective towards the omniscient, the higher the level of appropriation. Examples of this type of cross-cultural writing are A Passage to India, The Pearl, At Play in the Fields of the Lord, and Cry, the Beloved Country.

Complete cultural appropriation of identity occurs when the author uses a culturally heterogeneous character with a first-person point of view. In this instance, there is the least amount of psychic distance between the reader and the main character. The main character uses his own voice to narrate, direct, and focus the story. In this mode, the reader is able to observe the thinking and reasoning of the central character and observe how the character perceives his environment and how he thinks his environment perceives him. Examples of such appropriation are: Life of Pi, Memoirs of a Geisha, Good Scent from a Strange Mountain, and The Deportees.

In cross-cultural novels where the author uses a culturally heterogeneous central character, it therefore follows that the less psychic distance there is between a character and the reader, the greater is the level of cultural appropriation of identity.

Before discussing how one may appropriate identity, let us first briefly discuss the risks and benefits of cultural appropriation as it pertains to writing.


III. Risks and Benefits of Cultural Appropriation of Identity

There are benefits and disadvantages to cultural appropriation of identity in literature. On one hand, a writer who appropriates a cross-cultural identity may gain insight into the thinking and ways of another culture, which can contribute to his audience's understanding of that culture. The writing may create empathy in terms of race, social status, gender, religion, and/or cultural differences for which a humanist can argue that this understanding can directly and indirectly benefit society. Take for example the nonfiction work Black Like Me by John Howard Griffin in which a white man uses drugs and makeup to transform himself into a black man and then explores the racially divided, volatile American South of 1959. Because of the book's successful and meaningful appropriation, it is still required reading in many high schools across America, and had sold over ten million copies by 1996. On the other hand, in "Composing Race and Gender," Lia Silver notes the work Black Like Me begs a serious question: if a black man had written the same work without all the makeup, would it have been as powerful? Would it be a classic today had it not been an act of appropriation?

A writer's own race also plays a large part as to how well he can successfully appropriate another's identity. As noted by Silver as she refers to Helms and Cross: "It is not until individuals are secure with their own racial identity that they can feel secure enough to interact with other racial groups. Most people never reach this final stage of acceptance."1 This problem directly affects a novel's reading in terms of believability. The less interaction there is between writer and subject, or the less meaningful the interaction, the harder it will be for the writer to appropriate cultural identity.

Silver argues that certain groups in society are more likely to appropriate cultural identity than other groups. She says:

(The) likelihood and ease of fictional appropriation seems to decrease as the author's societal power decreases. This is largely related to those with less power feeling either inadequate or bound to represent the needs of their own societal group. Therefore, it tends to be less common for black people to appropriate a voice than for white people.2

On the other hand, those who support what is referred to as the "Romantic I" claim that an individual is free to write about whatever subject from whatever point of view. Consider the following opinion posted in a Canadian debate over cultural appropriation in literature as published in the Globe and Mail and quoted by Rosemary J. Coombe:

I reject the thought of cultural appropriation completely... I reject anything that limits the imagination. No one has the right to tell me who I should or should not write about, and telling me what or how I do that amounts to censorship... I am a man of East Indian descent and I have written from the viewpoint of women and black men, and I will continue to do so no matter who gets upset.3

Coombe points out that the writer of the above piece believes that themes, plots, ideas, and characters are at the whim of anyone who picks up a pen and that any interference is an attack on the creative impulse. Additionally, she argues that this line of thinking stems from liberal democracy's manifestation of possessive individualism supported through Western Civilization's current laws and thinking concerning the copyright laws. Another supporter of the right of appropriation in literature argued the importance of fusion in art:

The word "appropriation" ... has lately become a rhetorical weapon in the hands of intellectuals claiming to speak for minority rights. Its power derives oddly, from its very irrationality. In my experience, people hearing of it for the first time cannot believe that anyone would put forward so ludicrous an idea: even the most modest education in cultural history teaches us that art of all kinds has depended on the mixing of cultures.4

But as the following will prove, there are many who disagree with this line of thinking, and their argument is based on the remarkable history of misrepresentation and silencing of the Other.


IV. Framework for Analyzing Cultural Appropriation

In Borrowed Power: Essays on Cultural Appropriation, Pratima Rao and Bruce Ziff offer the following framework for analyzing cultural appropriation which will be the basis of our discussion:

  1. Cultural appropriation harms the appropriated community's identity and integrity.
  2. Seizure and commodification lessen a cultural object's power.
  3. Some benefit, others don't.
  4. Since current law does not protect the marginalized, this nonrecognition jeopardizes the appropriated community's sovereignty.5
The integrity of a group is damaged when that group lacks the power to define itself or even to criticize another group... The identity of a less powerful group involves issue of control.

1.a. Cultural appropriation harms the appropriated community's identity & integrity

Generalizations and stereotypes are included in a discussion on the misrepresentation of culture and the damage it does to identity. Garrett Hongo addresses such arguments in his preface to Under Western Eyes. "There is a tradition of misrepresentation with regard to the Other, and people of color sense it acutely, particularly when confronted with new outbreaks and hugely popular manifestations of it such as Miss Saigon, where the usurpation and stereotyping is so blatant."6 Included in misrepresentation are issues of naturalization, exoticization, and sexualization as exemplified in David Hyndman's analysis of National Geographic's photographs of the Melanesian Other (Hyndman) where he claims that the photography in National Geographic clearly highlights the photographers' conscious or unconscious attitudes towards the indigenous people they photographed.

In the preface to Under Western Eyes, Hongo discusses the role of power in appropriation as he reflects on a review he wrote of Gretel Ehrlich's novel Heart Mountain for the New York Times Book Review in 1998.

In my review I pointed out that the Japanese American male characters are portrayed as menacing, emasculated, or mystically benign while the principal Japanese American female character is portrayed as lissome and exotic, sexually available to whites. (...) (The) writing suffered from unconscious stereotyping and some historical ignorance.7

Hongo's analysis shows the misunderstandings many appropriators have of their subjects and thus supports Hongo's claims that the appropriator often asserts his dominance over his subject. The response Hongo received for his above review baffled him. He was deemed an "Ethnic hit-man," accused of taking a politically correct position and considered "radically ethnocentric." This response, he feels, also further underscores the power dynamics.

The integrity of a group is damaged when that group lacks the power to define itself or even to criticize another group as in Hongo's case. A dominant group's cultural appropriation of the identity of a less powerful group involves issues of control. Lenore Keeshig-Tobias argues that stories are more than entertainment; they are power. "They reflect the deepest, the most intimate perceptions, relationships and attitudes of a people. Stories show how a people, a culture, thinks. Such wonderful offerings are seldom reproduced by outsiders."8 She argues the identity of a group and the individual's role in that group are powerful in that they are indefinable to outsiders and may only be possessed and properly understood by a group member.

A white writer's cross-cultural novel is interpreted as a representation of how the appropriator views the appropriated. For the appropriated, how the dominant group views them, coupled with the appropriated community's lack of power to define themselves, determines the amount of damage done to their cultural integrity.

The appropriated community's damage is magnified when there is prior tension between the appropriator and the appropriated, as when the appropriated are marginalized in society. An example of this occurred in Australia, when the highly lauded aboriginal nonfiction writer Wanda Koolmatrie turned out to be a white Sydney cabbie named Leon Carmen. This caused not only a literary scandal, but a cultural scandal as well. A similar case occurred in the United Kingdom where the feminist publishing house Virago published a short story collection about Asians living in the U.K. written pseudonymously by a white male minister of the Church of England. Prior to publication, a female Asian editor questioned the authenticity of the work, having found the female Asian characters passive and the males aggressive.9 The lie was not found out until after publishing because Virago did not address the editor's concerns.


1.b. Response

Since the first-person point of view has the least amount of psychic distance and therefore the highest level of appropriation in cross-cultural novels, it follows that this mode can do the greatest amount of cultural damage to the appropriated. In this mode, it is easy for a reader to generalize that a given character's perceptions of the world are representative of the perceptions of the character's larger cultural group as to how they view and interact in the world. If a writer misrepresents an appropriated character, then damage is done to the appropriated culture. To limit the authority of my appropriated characters in my manuscript, I chose to use the third-person point of view thinking this would lessen the cultural damage. However, my novel has other damaging features that I had been unconscious of during the writing process. The novel possessed several poorly nuanced characters that could have easily been perceived as Asian stereotypes. According to Sheridan Prasso in The Asian Mystique, stereotypes like my own, conscious or unconscious, are all too common when Asian culture is appropriated. Prasso notes that:

When writers get to Asia, they are tempted and encouraged by their editors to write about a mystical, exotic world of difference that they imagined before their arrival, of images based in existing stereotypes and misperceptions. After all, that is what sells books and articles back home. I know because I, too, have been on the receiving end of editor's phone calls, asked to write stories from Asia that are different! Gripping! Exotic! Self-drenched!10

My main female character had been a young girl who was sold into prostitution. Having the option to live or die, the girl chose to live and to advance herself in her new world. Over the course of the novel, she developed into a character ready to use sex as power and a means for upward mobility. Another character had been a female storekeeper; a victim of an acid burn, she became a heartless businesswoman consumed by her need for power. Only after reading The Asian Mystique did I discover that my characters were actually stereotypes that I had unconsciously created during the writing process.

2.a. Seizure and commodification lessens a cultural object's power, or the application of bell hooks's methodology (There is No Such Thing as Ethical Cultural Appropriation)

The scholar bell hooks's work often identifies and explicates the workings of what she calls the "white supremacist capitalist patriarchy." Though she herself—to my knowledge—has not written on cultural appropriation in novels, she has written extensively on the appropriation of culture in general. Though she generally avoids discussions of cultural hybridity, she does argue time and again how the white supremacist capitalist patriarchy (hereafter referred to as the WSCP) steals the Other's culture and in doing so, silences them. hooks's cultural theory on the WSCP and the Other is based on the argument that America's ideas of free market gives the WSCP a sense of entitlement to appropriate and commodify culture and sell it to the masses. In turn, this process of commodification inherently devalues the appropriated culture. The underlying reason for this, hooks believes, is that the WSCP has conceived a relatively boring society typified by American life. As a result, she claims Americans suffer from adhedonia: the inability to feel pleasure. She correlates this desire for the Other and the idea that possession, or even consumption, will fill the void of the mundane.

In her essay "Eating the Other," hooks writes about how the white race gains pleasure through acknowledgement and exploration of the Other. Though she admits that the idea of whites valuing the Other can be cathartic, she also points out the damage that attention and exploitation can do. In fact, "Eating the Other," is a reference to the act of cannibalism which hooks cleverly links to consumerism as religion—the idea that one of power can rip out the beating heart of another and gain the strength, spirit, or favorable characteristics of the eaten. She says, "The commodification of Otherness has been so successful because it is offered as a new delight, more intense, more satisfying than normal ways of doing and feeling."12

One vehicle for escape that hooks does not discuss is the novel. She argues that novels of appropriation, from James Michener to Arthur Golden, if they are set in exotic and naturalized locales with exoticized and sexualized characters, may make money but are not ethical. hooks would read a white author's appropriation of an Other narrator as the WSCP affirming his power over the Other. Through the commodification of cultural identity, the author devalues the appropriated culture and makes the appropriated more susceptible to the WSCP machine.

"The power of signs, their power to ignite critical consciousness is diffused when they are commodified. Communities of resistance are replaced by communities of consumption."13

Though hooks believes "acknowledgement and exploration of racial difference can be... a challenge to white supremacy, to various systems of domination,"14 she would not condone the commodification of the Other's culture by the WSCP. "The over-riding fear," she says "is that cultural, ethnic, and racial differences will be continually commodified and offered up as new dishes to enhance the white palate-that the Other will be eaten, consumed, and forgotten."15

A writer's own race also plays a large part as to how well he can successfully appropriate another's identity

2.b. Response to hooks

According to hooks's logic, not only will a Cambodian writer not be able to write a similar story to that of mine, but her cultural icons will also have less of an impact on her audience. The personal narrative of Mineko Iwasaki, titled Geisha of Gion, illustrates this point. Ever heard of the Mineko or her book? Probably not, but we have all heard of Memoirs of a Geisha, written by the American William Golden. Golden interviewed Iwasaki while doing the research for his novel and credits her in the book's opening. Following a lawsuit, Iwasaki wrote her own story. Disregarding lawsuits and publication dates, a scholar might ask the ethical questions that hooks wants us to ask, and those are: 1. Does Golden lessen the iconic impact of geishas in his writing? 2. Who has a better right to the story: a geisha from Gion or a white guy from America? 3. Which is more true: a novel about a geisha by a white guy or a memoir by a geisha?

The Iwasaki/Golden example illustrates hooks's philosophy perfectly. Memoirs of a Geisha sold in the United States; Geisha of Gion did not. Once Memoirs of a Geisha claimed its share of the market in the United States, there was little room for Iwasaki. However, in Japan, the opposite occurred; the Japanese public chose the Iwasaki text rather than assimilation.

In my own writing, I have decided to continue my appropriation of the Cambodian identity and Cambodian culture, limited as it is, because of its relevance to my story about Americans living in Cambodia. I agree with hooks that in doing so I may be devaluing Cambodian iconography in American markets; however, I think hooks fails to see that in drawing attention to Cambodia, I may also open the door for Cambodian writers to step through. That is, writing opens a discussion; it does not end it.

3.a. Some benefit, others don't

Control is also seen in the act of publishing. Publishing inevitably means that some are heard and others are not. Philip argues that whites traditionally have the privilege and therefore the power to publish books and additionally, in a racist society, a white writer is typically better received than a black writer who writes on the same topic.16 Inevitably, some will benefit from the commodification of culture, and the argument follows that it is not right that those who benefit from the appropriation are always the powerful... the whites.

To those who would argue that in a democracy everyone has the right to write from any point of view, I would contend that for far too long certain groups have not had access to any of the resources which enable writing of any sort to take place, let alone writing from a particular point of view. Education, financial resources, belief in the validity of one's experiences and reality, whether working class, female, or black: these are necessary for the production of writing.17

In "Stop Stealing Our Stories," Ojibway storyteller Lenore Keeshig-Tobias accuses such authors as W.P. Kinsella and Darlene Barry Quaife of cultural theft, arguing that the stories told by the aforementioned are essentially retellings of native peoples who are themselves powerless to be heard. She does not see anything creative or original in such an act.


3.b. Response

After having considered the implications of appropriation of identity and culture in cross-cultural texts, writers who mean to appropriate culture and identity in novels must see that they have two obligations when they decide to appropriate: first, they must try to effect empathy for the appropriated culture rather than damage it; second, they must give back to the culture from which they appropriated.

Cultural appropriation of a voice is the most damaging in terms of exploiting individual and cultural identity. Again, for this reason, I chose not to write using the first-person point of view to limit the damage. In my story, the focus of the novel is on an American expatriate family living in Cambodia. The story follows the American family for seventy-five percent of the novel and a Cambodian prostitute for the remaining twenty-five percent. My purpose in using the Cambodian prostitute is to add another dimension to the story by shifting the point of view away from the perceptions of the Americans to how Cambodians perceive foreigners. I spoke with numerous nongovernment organizations that study prostitution and its effects in Cambodia and studied their annual reports in which they publish case studies of brothels and prostitutes in various provinces to create an accurate portrayal. My intention—rather than to exploit Cambodia and Cambodians by stealing their stories—is to show how the stereotypical male expatriate misinterprets and damages Cambodian culture. A Cambodian can still write a similar story with less psychic distance than I have done, and in fact, some have done so.

A writer who comes from a source of power has an obligation to help the voiceless. Perhaps this is why Robert Olen Butler offers links to Vietnamese sites on his website and regularly speaks at minority writers' conferences. Living in Cambodia for two years afforded me an opportunity to teach, engage, and contribute to life there in more positive ways than negative. But is this enough?

Consider that the Cambodian educational system has not recovered from the time of the Khmer Rouge. Sixty-three percent of the adult population is illiterate, and copyright laws are not enforced; it is difficult to make money as a writer. Even so, at any given time, The Khmer Writer's Association teaches more than 500 students enrolled in over twenty different classes.18

If the novel comes to press and I profit from this appropriation, am I not bound to contribute something back to such a Cambodian organization? Should I not also help enable a Cambodian to tell his/her story, one with less psychic distance and more gravity?


4.a. Since current law does not protect the marginalized, this nonrecognition jeopardizes the appropriated community's sovereignty

As Coombe points out, current copyright laws in many countries do not acknowledge cultural appropriation as illegal. When a state acts, it acknowledges; when it fails to act, it silences. It follows that Western Civilization's support of current copyright laws has silenced many cultures, but perhaps this will not always be the case.

With the help of various nations and even the United Nations, some cultures are beginning to copyright their respective culture's traditional folktales, songs, and art. In Australia, aboriginal designs are being copyrighted and protected against unethical use by The Model Law which overseas the "publication, recitation, performance, and distribution" of Aboriginal Folklore.19 In the United Nation's Draft Declaration on the Rights of Indigenous Peoples, Article 12 states that indigenous people have a right to

maintain, protect and develop the past, present and future manifestations of their cultures, such as (...) artifacts, designs, ceremonies, technologies and visual and performing arts and literature, as well as the right to the restitution of cultural, intellectual, religious and spiritual property taken without their free and informed consent or in violation of their laws, traditions and customs.20

And Article 29 recognizes "full ownership, control and protection of their cultural and intellectual property (oral traditions, literatures, designs, and visual and performing arts)."21 In Declaration of War Against Exploiters of Lakota Spirituality, Article Three reads, "We urge our people to coordinate with their tribal members living in urban areas to identify instances in which our sacred traditions are being abused, and then to resist this abuse, utilizing whatever specific tactics are necessary and sufficient-for example demonstrations, boycotts, press conferences, and acts of direct intervention."22


4.b. Response

In terms of literature, not all critics of cultural appropriation share these sentiments. Hongo argues that for so long, even the Other's criticism has been suppressed or discouraged due to social stigmas about speaking out. "To speak about trauma or social prohibition, to speak against silencing, can initiate further acts of trauma, silencing and prohibition of the speaker."23 Growing up, Hongo was not allowed to talk about Japanese internment camps for fear of controversy and vilification. "The Asian writer can be victimized by those who have themselves been silenced, by voices purporting to emerge from within ethnic communities, making exclusive claims to political truth and raising challenges against a given writer's ethnic authenticity." Hongo calls this "internalized oppression—manifestations of social oppression and the exercise of hierarchal political power that sometimes emerge from within enclave cultures of people of color."24 Even so, he does not believe in censorship. "There is a profound difference between the idea that any group has an exclusive right to engage in authorized acts of cultural representation and the idea that cultural representations are not open to criticism, whether by a group or an individual critic." Doing so would produce

yet another system of cultural silencing and, in microcosm of mirroring the mainstream, reproducing the tyrannical situation of group dominance over the individual artist. It is yet another form of cultural centrality that would itself create margins within cultural margin(s) (...).25


V. Conclusion

A cross-cultural writer who decides to appropriate identity in fiction must consider the consequences his writing will have on the appropriated community. The writer must assess how the writing may damage the appropriated community's identity and integrity, how commodification could negatively impact the appropriated community's culture, how the appropriated community might benefit, and whether or not the writer is reinforcing government mandated oppression aimed at the appropriated.

Finally, the appropriator of cross-cultural identity should consider the problems of translating the character's language, culture, and setting.

Feeling qualified, feeling that I have a right to tell my American story in Cambodia as long as I tell it well, I have decided to proceed in writing my manuscript. However, I have made several changes in the novel regarding characterization, focus, and translation.

I have also come to the conclusion that I should work further to help Cambodians achieve success in writing by supporting organizations like The Khmer Writer's Association in Cambodia.

Ultimately, the appropriator must realize a responsibility to the appropriated. This responsibility is not enforced by any governing body and will only be acted upon if that writer fully considers the ethics of his appropriation. Concluding with Philip:

Writers must be willing to learn; they must be open to having certainties shifted, perhaps permanently. They cannot enter as oppressors, or even as members of the dominant culture. That sense of humility is what has been sorely lacking in the deluge of justifications that have poured forth in support of the "right" of white writers to use any voice.26


Stephen J. Quigley recently published "Translating Language, Culture, and Setting in Cross Cultural Writing" in New Writing, The International Journal for the Practice and Theory of Creative Writing and "The Fate of the Ash Hunley in a Global Economy" for Irish Studies Review.

  1. Silver, Lia. 2006. "Composing Race and Gender: The Appropriation of Social Identity in Fiction." Thesis, Miami University, 10-11.

  2. Ibid., 31.
  3. Coombe, Rosemary J. "The Properties of Culture and the Possession of Identity: Postcolonial Struggle and the Legal Imagination," in Borrowed Power: Essays on Cultural Appropriation, edited by Bruce Ziff and Pratima Rao (New Brunswick: Rutgers University Press, 1997), 76-7.
  4. Qtd by Bruce Ziff and Pratima Rao. Introduction to Borrowed Power: Essays on Cultural Appropriation (New Brunswick: Rutgers University, 1997), 8.
  5. Ziff et al. 3-26.
  6. Hongo, Garrett. 1995. Introduction to Under Western Eyes (New York: Anchor Books), 6.
  7. Ibid., 7.
  8. Keeshig-Tobias, L. "Stop Stealing Native Stories," in Borrowed Power: Essays on Cultural Appropriation, edited by Bruce Ziff and Pratima Rao (New Brunswick: Rutgers University Press, 1997), 71-3.
  9. Philip, Nourbese. "The Disappearing Debate; or, How the Discussion of Racism has been Taken Over by the Censorship Issue," in Borrowed Power: Essays on Cultural Appropriation, edited by Bruce Ziff and Pratima Rao (New Brunswick: Rutgers University Press, 1997), 106.
  10. Prasso, Sheridan. The Asian Mystique (New York: Public Affairs, 2005), 393.
  11. Prasso, 87.
  12. hooks, bell. "Eating the Other," in Black looks: Race and representation. (Boston: South End Press, 1992), 21.
  13. hooks, 33.
  14. hooks, 39.
  15. Ibid.
  16. Phillip, 106-7.
  17. Phillip, 101.
  18. Cameron, Amy. "Pulp Fiction," Phnom Penh Post, 25 February – 10 March 2005, 16.
  19. Blakeney, Michael. "Intellectual Property in the Dreamtime-Protecting the Cultural Creativity of Indigenous People," Research Seminar, 9 November 1999. Oxford Intellectual Property Research Centre, 1999,, 9, (1 May 2006).
  20. Blackney, 14.
  21. Blackney, 12.
  22. Elk, Darrell Standing, Wilmer Stampede Mesteth, and Phyllis Swift Hawk. "Declaration of War Against Exploiters of Lakota Spirit," American Indian Cultural Support, (1 May 2006).
  23. Hongo, 8.
  24. Hongo, 15.
  25. Hongo, 31.
  26. Phillip, 107.

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