case, original artistic skill and labor. 61 If the House of Lords further elaborates on this test, it may get to
a clear creativity-based test, because "original skill and labor" cannot have the same meaning as "skill and
labor." 62 We suggest, therefore, that the Express Newspapers case 63 might have to be reconsidered. The
introduction of originality in the Statute cannot be meaningless. In other words, if "original" means
something, which it must, it is more than mere skill and labor, and that additional element is likely the
intellectual creativity which seems to be required by EU directives. 64 The expression "author's own
intellectual