ISSUE:
Whether the work of the reporters be considered to be ‘original’?
Whether the reporters could be considered authors concerning copyrights?
RULE:
According to the Doctrine of Sweat of the Brow, an author acquires rights through diligence and effort while producing a work, such as a database or directory. To obtain copyrights, "originality" is not necessary. Even if work is completely unoriginal, its creator is entitled to compensation under the "sweat of the brow” to protect the efforts.