S&B successfully defended a client sued in federal court for copyright infringement. S&B argued that the subject "work," consisting of a compilation of factual data, was not protectable under the Copyright laws. Based upon that, S&B obtained a quick dismissal of the case. "Not everything that someone creates is entitled to Copyright protection," William Buus said. "There are limits. It is well-settled law that a "work" must contain a least a minimal amount of creativity or originality. A simple listing or compilation of data, without more, is not copyrightable."