The area of literary rights is confusing for scholars whose work focuses on collaborative materials particularly materials of earlier Native American writers. Questions arise over authorship and the determination of literary heirs. For example, recognition of heirs turns on the European-based assumption of the private ownership of a written statement. The first person to write down an oral tale can become legally recognized as the owner of that version of the story, just as the first chemist to patent a tribal healing practice becomes the owner of the resulting chemical formula. This instance on private rather than collective ownership, derived from the nineteenth-century notion of the autonomous, creative, authorial voice, flies in the face of those who come from an oral tradition. Thus a scholar concerned with finding literary heirs in order to afford them the benefits of copyright laws must in so doing accede to legal concept of ownership that has been used to appropriate knowledge from community-based cultures.