Telstra Corporation Limited v Phone Directories Company Pty Ltd [2010] FCA 44 (8 February 2010)
"Even if the authors of the Works could be identified with sufficient clarity and certainty (and they cannot), the people suggested to be the authors of the Works did not exercise “independent intellectual effort” and / or “sufficient effort of a literary nature”. A majority of the creation process of the WPD and the YPD was heavily automated. Human intervention was regulated and controlled according to either the various computer systems in place including the Rules (see Part V Sections B and C above). Further, the contribution of the people suggested to be authors of the Works was anterior to the work taking its material form. Very few people had any part to play in the final presentation of the Works or the particular form of expression of the information. Those people, again, could not have been said to have exercised “independent intellectual effort” and / or “sufficient effort of a literary nature”: see [20(3)] above."