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Case file s436 · Literature and art · 2010
2010
J. D. Salinger: J. D. Salinger (Catcher in the Rye portrait)
J. D. Salinger. Lotte Jacobi. Public domain, Wikimedia Commons.
Died
27 January 2010
Place
Cornish, New Hampshire · United States
Field
novelist · Literature and writing on the timeline
Legal tradition
US copyright law, Second Circuit · Common law
Historical event
eBay v. MercExchange and the law on injunctions
Religion
J. D. Salinger: Buddhist, Hindu, Jewish, Other Christian (recorded as Zen, Judaism on Wikidata; American Hindus, Converts to Christianity from Judaism, Converts to Hinduism on Wikipedia)

J.D. Salinger blocked an unauthorised Catcher in the Rye sequel, and his estate settled to keep it out of North America until the copyright ends

In 2009 the Swedish writer Fredrik Colting published 60 Years Later: Coming Through the Rye, featuring an aged Holden Caulfield†. Salinger sued, and a federal judge in New York blocked US publication†. Salinger died in January 2010. On 30 April 2010 the Second Circuit vacated the injunction. It held that courts may no longer presume irreparable harm in copyright cases and must apply the four-factor test from the Supreme Court's eBay ruling. It still found Salinger likely to win on the merits, and sent the case back. In December 2010 or 2011† the estate and Colting settled. Colting agreed not to publish or distribute the book, in any edition, in the US or Canada until The Catcher in the Rye enters the public domain. He remained free to sell it elsewhere. Terms are confidential. Salinger's son Matt and widow Colleen control the estate† and have said he left unpublished work†.

What the law took from it

A litigation strategy set by the author can be carried on by the estate, and settlement can trade a worldwide ban for a regional one.

Cite as: celebrity.estate, “J.D. Salinger blocked an unauthorised Catcher in the Rye sequel, and his estate settled to keep it out of North America until the copyright ends,” story s436, https://www.celebrity.estate/j-d-salinger-2010, updated 30 October 2026.

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