the author's own intellectual creation. This threshold for originality is harmonised within the European Union by the European Court of Justice in Infopaq International A/S v Danske Dagblades Forening case. Germany In German copyright law, the "Schöpfungshöhe" (literally: height of creation) could classify copyrightable works into two classes, a design, or anything else (such as a literary work). While the threshold (which is reached even by simple creations, known as "Kleine Münze", German for "Small change") was low, the requirements for design, works that have a "purpose" (such as brand identification), was set much higher, as "novel" designs could be protected by the lex specialis law for design patents ("Geschmacksmustergesetz") or by trademark laws. Only design creations that were very high above the average were considered to be "works of applied art" and so granted copyright. As an example in case law, the logo of the German public broadcaster ARD, was considered ineligible for protection under German copyright law. In November 2013, the Federal Court of Justice rejected the concept of a lower standard for applied artworks in the Geburtstagszug case. The court ruled that per changes made to German law in 2004 by the implementation of the Directive on the legal protection of designs, copyright and design right were two separate concepts that could co-exist in applied art, as they had different requirements; novelty and an "individual character" for design right, and "a degree of creativity which allows, from the view of a public open to art and sufficiently skilled in ideas of art, to be called an 'artistic' performance", for copyright. This makes the threshold nearly identical to that in other forms of works. The case centred around the creator of the "Birthday Train", who had received royalties from a design patent but wanted to also collect royalties on the concept as a copyrighted work. In June 2016, a state court ruled in a complaint against the Wikimedia Foundation by the Reiss Engelhorn Museum, that digital reproductions of public domain works are subject to a new copyright. Netherlands A controversial decision on 16 July 2013 rendered "backseat conversations"—such as those between Willem Endstra and police—not sufficiently creative for copyright protection. India Section 13(1)(a) of the Indian Copyright Act, 1957 mentions 'originality' as a requirement for copyright protection to literary, dramatic, musical and artistic works. Courts have interpreted this requirement of 'originality' in different ways. This has given rise