In the 1915 case G. & C. Merriam Company v. Saalfield and Ogilvie, the U.S Supreme Court dealt with a copyright dispute between two publishing companies over Noah Webster's dictionary. The plaintiff, G.&C Merriam Company had purchased exclusive rights to publish the dictionary from Webster’s heirs in 1843 and continuously published it since then, making revisions as necessary to keep it up-to-date while maintaining its original character. The defendants were accused of infringing on this copyright by publishing their own version of the dictionary that closely resembled that of the plaintiffs'. However, they argued that because most content was derived from public domain sources or consisted of common knowledge facts such as definitions or pronunciations which are not subject to copyright protection; therefore no infringement occurred. The court ruled in favor of defendants stating that although there may be considerable labor and skill expended in compiling such information into a convenient form for use like a dictionary but these efforts do not transform non-copyrightable material into something protected by copyright law.

The dissenting opinion in the case of G. & C. Merriam Company v. Saalfield and Ogilvie argued that the majority's decision to uphold copyright protection for a dictionary was incorrect because it failed to recognize that dictionaries are fundamentally compilations of facts, which cannot be copyrighted under U.S law. The dissenting justices believed that while individual entries or definitions could potentially be protected if they demonstrated sufficient originality, the overall structure and organization of a dictionary did not meet this standard. They contended that allowing such broad copyright protections would stifle competition and innovation in the publishing industry by granting monopolies over basic factual information.