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Rather infamously, Melville was paid a grand total of less than $600 for his masterpiece Moby Dick.
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I guess this more or less matches to what Wikipedia says:
The book never sold its initial printing of 3,000 copies in his lifetime, and total earnings from the American edition amounted to just $556.37 from his publisher, Harper & Brothers.
As I calculate it, this means he was paid about $5.00 a copy in 2012 dollars. Tax free.
Lack of advertising? It's hard to do strong advertisements for a book that got uniformly bad reviews.
Do any of the self-published authors here want to share with us how much money they clear for books selling under 3,000 copies over a period of many years?
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This could end up being extraordinarily bad news for Penguin, MacMillan and Apple if they actually force an annoyed DOJ into court.
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Or not, since the Justice Department wins about half of anti-trust cases that go to trial. Anyone who is sure what a court would decide doesn't understand the situation.
P.S. Melville didn't need Smashwords. He needed an agent.