In the case of Bates & Guild Co. v. Payne, 1903, the United States Supreme Court ruled on a copyright dispute between two publishing companies over photographs used in their respective publications. The plaintiff, Bates & Guild Co., alleged that the defendant, Payne, had infringed upon their copyright by using similar photographs without permission or compensation. However, it was found that both parties had obtained these images from a common source - an artist who held no exclusive rights to them and sold copies freely to anyone interested in purchasing them. The court concluded that there was no infringement as neither party could claim exclusive rights to the images since they were not original works but rather reproductions of public domain art pieces (specifically sculptures). Therefore, even though Bates & Guild Co.'s publication came first and they held a valid copyright for their specific arrangement and selection of photos within it; this did not extend protection against others using individual photos from same non-exclusive source in different arrangements or contexts.

In the dissenting opinion for Bates & Guild Co. v. Payne, it was argued that copyright protection should not extend to a mere arrangement of uncopyrighted material. The justice believed that granting such extensive rights would be contrary to the purpose of copyright law, which is intended to encourage creativity and innovation by protecting original works of authorship. He contended that allowing a party to monopolize an idea or method through copyright would stifle competition and hinder progress in arts and sciences - areas where advancement relies heavily on building upon existing knowledge or techniques. Furthermore, he expressed concern about potential abuse if copyrights were granted too broadly, as this could lead to undue restrictions on public access to information and ideas.