In the 1908 case of Bong v. Alfred S. Campbell Art Company, the U.S Supreme Court dealt with a dispute over copyright infringement. The plaintiff, Bong, accused Alfred S. Campbell Art Company of infringing on his copyrighted photograph by reproducing and selling it without permission or compensation to him. The defendant argued that they had purchased copies of the photograph from a third party who claimed to have obtained them legally from Europe where there was no copyright protection for such works at that time due to lack of international copyright agreements between countries involved in this case (the United States and Germany). However, the court ruled in favor of Bong stating that regardless if an item is bought abroad where it's not protected by copyrights laws doesn't mean one can reproduce and sell it freely in America as American Copyright law still applies once within its borders.

The dissenting opinion in the case of Bong v. Alfred S. Campbell Art Company argued that the majority's decision was incorrect because it failed to properly interpret and apply copyright law. The dissent believed that a photograph, which is an original work of art, should be protected under copyright laws regardless of whether or not it has been registered with the Copyright Office. They contended that registration should only serve as evidence of ownership rather than a prerequisite for protection under law. Furthermore, they disagreed with the majority's view on foreign works; arguing instead that U.S copyright laws should protect them if they are published in America without any formalities being required from their authors abroad.