308.2 Creativity
A work of authorship must possess “some minimal degree of creativity” to sustain a
copyright claim. Feist, 499 U.S. at 358, 362 (citation omitted).
“[T]he requisite level of creativity is extremely low.” Even a “slight amount” of creative
expression will suffice. “The vast majority of works make the grade quite easily, as they
possess some creative spark, ‘no matter how crude, humble or obvious it might be.’” Id.
at 346 (citation omitted).
