[I]t is almost unanimously accepted that a scholar can make a handwritten copy of an entire copyrighted article for his own use, and in the era before photoduplication it was not uncommon (and not seriously questioned) that he could have his secretary make a typed copy for his personal use and files. These customary facts of copyright-life are among our givens.
Williamson & Wilkins v. United States, 487 F2d 1345, 1350 (Ct. C. 1973)
Personality always contains something unique. It expresses its singularity even in handwriting, and a very modest grade of art has in it something irreducible, which is one man’s alone. . . .
Bleistein v. Donaldson Lithographing Co., 188 U.S. 239, 249 (1903) (Holmes, J.)
Whose copying work counts as creative?