To make the emulation interface required the new program to copy both the command headers and some organization from the market leader. The latter company sued for copyright infringement, but lost. The First Circuit held that the copied commands and their hierarchy were “methods of operation.” Given the statutory command that “In no case does copyright protection for an original work of authorship extend to any . . . , method of operation . . .,” the First Circuit held that the command hierarchy could be copied. Further, the court explained, “The fact that developers of the Lotus spreadsheet program could have designed its menu command hierarchy differently is immaterial to the question of whether the menu hierarchy is a “method of operation.” "