727.2 Copyrightable Authorship in Databases
The legislative history for the Copyright Act states that “computer databases” may be protected by copyright “to the extent that they incorporate authorship in the programmer’s expression of original ideas, as distinguished from the ideas themselves.” H.R. REP. NO. 94-1476, at 54 (1976), reprinted in 1976 U.S.C.C.A.N. at 5667. Single-file or multi-file databases typically contain the following forms of authorship:
• The selection authorship involved in choosing the material or data that is included in the database.
• The coordination authorship involved in classifying, categorizing, ordering, or grouping the material or data.
• The arrangement authorship involved in determining the placement or arrangement of the material or data within the database as a whole.
• The authorship involved in creating the material or data that appears within the database.
Each form of authorship may be registered with the Office, provided that the database contains a sufficient amount of original expression and provided that the claimant owns the copyright in that material.