The United States Court of Appeals for the Second Circuit reviewed a
similar argument concerning news abstracts in Nihon Keizai Shimbun, Inc. v.
Comline Business Data, Inc.200 The court held that it is not infringement for an
abstract to directly copy one paragraph from a six-paragraph-foreign-language
article.201 Comline Business Data, similar to a commercial aggregator, creates
abstracts of news articles from a variety of sources.202 Although facts lack the
originality to be copyrightable creative expressions, compilations of facts may
have protection because they “display originality in their selection,
arrangement, or presentation . . . .”203 Furthermore, through the description of