In the 1936 case of Prairie Farmer Publishing Co. et al. v. Indiana Farmer's Guide Publishing Co., the U.S Supreme Court ruled in favor of Prairie Farmer Publishing, upholding their right to use a specific circulation plan without interference from competitors. The dispute arose when both companies sought to implement similar plans that involved giving away free copies of their publications as part of a strategy to increase advertising revenue by boosting circulation numbers. Indiana Farmer's Guide claimed this constituted unfair competition and sued for an injunction against Prairie’s plan, arguing it would cause irreparable harm due to lost advertisers and subscribers if allowed to proceed. The court disagreed with these claims, stating that there was no evidence showing any intent on Prairie’s part to drive its competitor out of business or monopolize trade through predatory practices; rather they were simply trying innovative methods for increasing profits in a competitive market environment where such tactics are common practice among businesses seeking growth opportunities within their industry sector.

The dissenting opinion in the case of Prairie Farmer Publishing Co. et al. v. Indiana Farmer's Guide Publishing Co., 1936, argued that the majority had incorrectly applied copyright law and failed to adequately consider precedent cases regarding derivative works and compilations. The dissent contended that a mere change in format or medium does not constitute sufficient originality to warrant a new copyright, as it does not involve any creative effort or intellectual production on part of the author. Furthermore, they believed that granting such copyrights would create monopolies over public domain information and stifle creativity by limiting access to these materials for other authors who may wish to use them in their own works.