facts, there is some room for originality within news articles due to an author’s
choice of words, analysis of events, and structure of materials.204 Although the
abstract at issue in the case used a literal translation of one paragraph from a
six-paragraph article,205 the court found that the abstract was not substantially
similar in a quantitative sense. It did, however, find that other summaries by
Comline which copied more than half of articles constituted infringement.206
Thus, a shorter, highly-factual text, such as a news headline, may fall under
copyright exceptions, but as the text becomes longer, such as an excerpt or
lead, the exception argument becomes more difficult to make.