Pursuant to Section 102a of the

US Copyright Act

(USC), a work may be registered if it qualifies as an original work of authorship fixed in any tangible medium of expression. In this context, the term “original” has two components: independent creation and sufficient creativity (

Feist

). The work must have been independently created by the author, i.e. not copied from another work. In addition, the work must possess sufficient creativity. Only a limited amount of creativity is necessary, but works like the alphabetized telephone directory at issue in

Feist

would fail to even reach this low threshold.