he purpose of copyright law is to reward those who produce new works and new expressions of ideas. However, this does not mean that copyright should be granted in all circumstances where there has been labor involved in the creation of some sort of expression. Only expression that is creative is the proper subject matter for the protection of copyright.
To argue otherwise would be akin to saying that because the purpose of having a burglary law is to protect the actual property of persons, even in cases where a person’s property was taken as a result of fraud, the perpetrator of the
crime should be punished under the law prohibiting burglary. Some courts have done precisely this by applying a test of merely skill and labor to determine whether works are copyrightable, and ignoring the requirement that there must
be some creativity involved to make it copyrightable