Is there a Feist ghost in the copyright machine? Feist did not purport to create a new standard of
originality; instead, it restated a well-known standard, already described albeit not as "clearly" in Burrow-
Giles Lithographic Co. v. Sarony and the Trademark Cases. In fact, as we have seen, the creative
selection standard was already applied in at least three circuits. The legislative history of the 1976
Copyright Act shows that originality is required and involves something other than ingenious and