In decisions issued two days apart, the U.S. Court of Appeal for the Seventh and Ninth Circuits expressed divergent views on the scope of copyright protection for collections of standard or generic elements. Following a recent case of its own, the Ninth Circuit affirmed that such works are entitled to only "thin" protection. In an analogous case, the Seventh Circuit articulated a broader scope of protection, holding that copyright protection lies even where minimal original elements are added to standard elements.
In Bucklew v. Hawkins, Ash, Baptie, & Co., Case Nos. 02-2244, 02-2299, 2003 U.S. App. LEXIS 10485 (7th Cir. May 27, 2003), Bucklew charged two affiliated companies (HAB) with infringing his copyright in software designed for use with standard spreadsheet applications for generating tables for use with forms required by the U.S. Department of Housing and Urban Development (HUD). Bucklew did not claim a copyright over the spreadsheet per se, but claimed protection for such
