Ellen Lee accused Sontag of plagiarism when Lee discovered at least twelve passages in In America (1999) that were similar to, or copied from, passages in four other books about Helena Modjeska without attribution.[54][55] Sontag said about using the passages, "All of us who deal with real characters in history transcribe and adopt original sources in the original domain. I've used these sources and I've completely transformed them. There's a larger argument to be made that all of literature is a series of references and allusions."[56]
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