Feist Publications, Inc. v. Rural Tel. Service Co. 499 U.S. 340 (1991) involved competing publications of telephone directories, and the justices construed the federal Copyright Act of 1976, an act in which Congress provided a definition for the term "compilation." A compilation is "a work formed by the collection and assembly of preexisting materials . . . that are selected, coordinated, or arranged in such a way that the resulting work, as a whole, constitutes an original work of authorship."(Id., 356, citing 17 U.S.C. 101.) The Supreme Court held that the plaintiff's alphabetical arrangement of residents' names in the white pages of its telephone directory was not sufficiently original because arranging names alphabetically is an "age-old practice, firmly rooted in tradition and so common place that it has come to be expected as a matter of course." Id. at 1297. The Supreme Court articulated the level of copyright protection afforded to compilations: "A factual compilation is eligible for copyright if it features an original selection or arrangement of facts, but the copyright is limited to the particular selection or arrangement. In no event may the copyright extend to the facts themselves." For the selection or arrangement to be deemed "original," only a minimal degree of creativity is required. (Id. at 358.) The Court reaffirmed the principle that copyright protection should be granted to original compilations of fact. An original compilation is defined as one involving the collection and assembly of preexisting data, the selection, coordination or arrangement of that data, and a resulting work that is original by virtue of the selection, coordination or arrangement of the data contained in the work. The Supreme Court concluded that, while a telephone directory as a whole may be subject to a valid copyright "because it contains some foreword text, as well as original material in its yellow pages advertisements," the subscriber information contained in the White Pages "lacked the modicum of creativity necessary to transform mere selection into copyrightable expression." The Court analyzed the copyrightability of compilations of facts. It pointed out that "facts are not copyrightable" but "compilations of facts generally are." (499 U.S. at 344.) The compilation author typically chooses which facts to include, in what order to place them, and how to arrange the collected data so that they may be used effectively by readers. These choices as to selection and arrangement, so long as they are made independently by the compiler and entail a minimal degree of creativity, are sufficiently original that Congress may protect such compilations through the copyright laws. (499 U.S. at 348.) The Supreme Court noted that "original, as the term is used in copyright, means only that the work was independently created by the author (as opposed to copied from other works), and that it possesses at least some minimal degree of creativity." (499 U.S. 340, 345). The Court noted that "the requisite level of creativity is extremely low" and that "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." (Feist, 499 U.S. at 345.) The Supreme Court explained: The question that remains is whether the appellee selected, coordinated, or arranged these uncopyrightable facts in an original way. As mentioned, originality is not a stringent standard; it does not require that facts be presented in an innovative or surprising way. It is equally true, however, that the selection and arrangement of facts cannot be so mechanical or routine as to require no creativity whatsoever. The standard of originality is low, but it does exist. As this Court has explained, the Constitution mandates some minimal degree of creativity, and an author who claims infringement must prove "the existence of . . . intellectual production, of thought, and conception." (Feist., 499 U.S. at 362.) The U.S. Supreme Court had occasion to decide the scope and extent of copyright protection available to compilations. "The mere fact that a work is copyrighted does not mean that every element of the work may be protected. Originality remains the sine qua non of copyright; accordingly, copyright protection may extend only to those components of a work that are original to the author . . . Thus, if the compilation author clothes facts with an original collocation of words, he or she may be able to claim a copyright in this written expression. Others may copy the underlying facts from the publication, but not the precise words used to present them." (Feist., 499 U.S. at 348.) The Supreme Court explained that "the requisite level of creativity is extremely low; even a slight amount 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 345 The Court held that copyright protection in the selection, coordination and arrangement of otherwise uncopyrightable elements is "thin" because the scope of the copyright is limited to the particular selection or arrangement. (Id. at 349-51) Furthermore, a "subsequent author remains free to use the public domain elements to aid in preparing a competing work, so long as the competing work does not feature the same selection and arrangement." Id.