This is referred to as the "sweat of the brow" doctrine in relation to the idiom, "the sweat of one's brow". The sweat of the brow doctrine has been recognised at various times in the United Kingdom, Canada, Australia, and elsewhere. The 1900 UK case Walter v. Lane ruled that the copyright of an account of a speech transcribed by a reporter belonged to the newspaper he worked for because of the effort it took to reproduce his spoken words. Courts in the United States rejected this notion in Feist Publications v. Rural Telephone Service (1991) and Bridgeman Art Library v. Corel Corp. (1999). In these cases, the courts asserted that originality was required for copyright protection. Since the Feist decision, many common law countries have moved towards applying a similar standard. A similar precedent was set in Canada by cases such as Tele-Direct (Publications) Inc. v. American Business Information Inc. (1997), where the court concluded that compilations of data must embody originality and creativity in order to be copyrighted. In March 2012, the European Court of Justice also set a similar precedent, ruling that Football DataCo could not claim copyright on association football match schedules due to the skill and labour used in their creation, as their compilation is "dictated by rules or constraints which leave no room for creative freedom". In November 2015, the United Kingdom's Intellectual Property Office clarified that it was "unlikely" that a digitised reproduction of a work out of copyright would be original enough to attain a new copyright. See also Commons:Threshold of originality Commons:Commons:Derivative works Derivative works References Further reading Justin Hughes: The Philosophy of Intellectual Property in: Georgetown Law Journal, Vol. 77, 1988, pp. 6–28 Peter Drahos: A Philosophy of Intellectual Property, Dartmouth Publishing, 1996, Elizabeth F. Judge/Daniel Gervais: Of Silos and Constellations: Comparing Notions of Originality in Copyright Law, in: Cardozo Arts & Entertainment Law Journal, Vol. 27, 2009, pp. 375–408, (PDF version). Orit Fischman Afori: The Role of the Non-Functionality Requirement in Design Law, in: Fordham Intellectual Property, Media & Entertainment Law Journal, Vol. 20:3, 2010 pp. 847–874, (PDF version). Eva E. Subotnik: Originality Proxies: Toward a Theory of Copyright and Creativity., in: Brooklyn Law Review, Vol. 76:4, 2010, pp. 1552. Carys J. Craig: Copyright, Communication and Culture: Towards a Relational Theory of Copyright Law, Edward Elgar Publishing, . Estelle Derclaye: Wonderful or worrisome? The impact of the ECJ ruling