In the 1914 case of G. & C. Merriam Company v. Syndicate Publishing Company, the U.S Supreme Court ruled in favor of G. & C. Merriam Company, a dictionary publisher who had sued Syndicate Publishing for copyright infringement over their use of Webster's Dictionary content without permission or proper citation in their own publications. The court held that while individual words and definitions cannot be copyrighted as they are considered common property, the specific arrangement and selection of those words can be protected under copyright law if it involves originality and labor on part of the author/publisher. Syndicate Publishing argued that they were merely using public domain information from an older edition not covered by current copyrights but evidence showed substantial copying from newer editions owned by Merriam which led to this ruling.

In the dissenting opinion for G. & C. Merriam Company v. Syndicate Publishing Company, it was argued that copyright protection should not be extended to a work merely because of minor alterations or additions made to an existing public domain work. The justice emphasized that the majority's decision could potentially allow publishers to perpetually renew their copyrights by making insignificant changes and claiming them as new works deserving of fresh copyright protection. This would undermine the purpose of copyright law, which is intended to encourage creativity and innovation rather than simply reward repetitive labor on pre-existing materials in public domain.