While that might be true, it's not really relevant to the underlying point, which is the selection and arrangement of non-copyrightable material can result in a

While that might be true, it's not really relevant to the underlying point, which is the selection and arrangement of non-copyrightable material can result in a copyrightable work. You can replace recipes with any other example if you'd like. > Even when applying copyright to an "arrangement" of items that are not copyrightable, as in a database, there needs to be creativity expressed, otherwise it will not qualify for copyright. As the Supreme Court said in Feist: "To be sure, the requisite level of creativity is extremely low; even a slight amount will suffice." This is not a very difficult threshold to meet (and Google has already conceded it has been met.)