The U.S. Supreme Court case Feist Publications, Inc. v. Rural Telephone Service Co., Inc., 1990 revolved around copyright infringement in relation to telephone directory listings. Rural Telephone Service Company had compiled a phone book for its customers and refused to license the information to Feist Publications, which was creating a regional directory. Consequently, Feist used the data without permission and was sued by Rural for copyright infringement. The Supreme Court ruled in favor of Feist stating that facts cannot be copyrighted because they are not original works; therefore no creative effort went into compiling them - it's merely an exercise of labor, skill or judgment which is insufficient to qualify for intellectual property protection under US law.

In the dissenting opinion for Feist Publications, Inc. v. Rural Telephone Service Co., Inc., Justice Blackmun argued that the majority's decision to deny copyright protection to factual compilations was a departure from established precedent and Congressional intent. He contended that while facts themselves are not copyrightable, significant effort goes into compiling these facts in a useful manner which should be protected under copyright law as "sweat of the brow" doctrine suggests. The majority’s ruling could discourage entities from creating such databases due to lack of protection against copying by others, thereby inhibiting progress rather than promoting it as intended by Copyright Act. Furthermore, he believed that this issue would have been better addressed through legislative action rather than judicial interpretation.