Are compilations of facts such as phone directories copyrightable?
Yes, but very thinly. Facts themselves are not copyrightable, and compilations can only be copyrighted for the originality of their selection and arrangement. That said, of course, if the compilation has elements in it (such as news articles) that are not facts and are indeed copyrightable themselves then those elements must be left out. The court specifically denies “sweat of brow” arguments relating to the efforts of the compiler in the 1976 Copyright act. For a complete discussion of this topic see Feist Publications v. Rural Telephone Service.
