theory that works of authorship need a hedge or moat around them to assure adequate protection. But that does not appear to be the law. The White-Smith case also appears to be the source of a legal metaphor used in US patent law relating to computer programs. As explained in greater detail in the Wikipedia article Piano Roll Blues, the legal fiction developed in US patent law that placing a new program in an old general-purpose digital computer creates a new computer and thus a "new machine" for purposes of section 101 of the US patent statute (listing patent-eligible subject matter). Critics of this argument derisively termed it the "Old Piano Roll Blues," meaning that the argument was equivalent to asserting that placing a new piano roll into an old player piano transformed it into a new player piano. The 2014 decision of the United States Supreme Court in Alice Corp. v. CLS Bank International appears to have extinguished the Piano roll blues argument by holding that simply saying “apply it with a computer” will not transform a patent-ineligible claim to an idea into a patent-eligible claim. See also List of United States Supreme Court cases, volume 209 White, Smith & Company References External links "Player Pianos and the Origins of Compulsory Licensing – Some Details of its Origins" by Zvi S. Rosen United States Supreme Court cases United States copyright case law 1908 in United States case law United States Supreme Court cases of the Fuller Court Abrogated United States Supreme Court decisions