APIs "as needed to include tasks that would be useful in smartphone programs". The amount and substantiality of the copyrighted material: Breyer said that Google only used about 0.4% of the total Java source code and was minimal. On the question of substantiality, Breyer wrote that Google did not copy the code that was at the heart of how Java was implemented, and that "Google copied those lines not because of their creativity, their beauty, or even (in a sense) because of their purpose. It copied them because programmers had already learned to work with [Java SE], and it would have been difficult … to attract programmers to … Android … without them." The market effect of the copyright-taking. Breyer said that at the time that Google copied the Java APIs, it was not clear if Android would become successful, and should not be considered as a replacement for Java but as a product operating on a different platform. Breyer further stated that if they had found for Oracle, it "would risk harm to the public", as "Oracle alone would hold the key. The result could well prove highly profitable to Oracle (or other firms holding a copyright in computer interfaces) ... [but] the lock would interfere with, not further, copyright's basic creativity objectives." Breyer determined that Google's use of the APIs had met all four factors, and that Google used "only what was needed to allow users to put their accrued talents to work in a new and transformative program". Breyer concluded that "we hold that the copying here at issue nonetheless constituted a fair use. Hence, Google's copying did not violate the copyright law." This conclusion rendered the need to evaluate the copyright of the API unnecessary. Justice Clarence Thomas wrote a dissenting opinion that was joined by Justice Samuel Alito. Thomas wrote that the majority opinion created a new distinction between implementing code and declaring code that Congress had rejected, and thus, "the result of this distorting analysis is an opinion that makes it difficult to imagine any circumstance in which declaring code will remain protected by copyright." Thomas further stated that in his own fair use analysis that "Google's use of that copyrighted code was anything but fair". Impact Google v. Oracle was a closely watched case by the tech industry. A ruling favoring Oracle could have had significant effects on past and future software development