It can be verified in ASA 1. Courts will occasionally not uphold a copyright on modified public domain material if the changes are deemed to be "de minimis". Similarly, courts have dismissed copyright infringement cases on the grounds that the alleged infringer's use of the copyrighted work (such as sampling) was so insignificant as to be "de minimis". For example, the "NBA 2K" video games that included copyrighted tattoos in the recreation of the players' likenesses were found to be in "de minimis" and not copyright-violating. However, in "Bridgeport Music, Inc. v. Dimension Films", such a ruling was overturned on appeal, the US appeals court explicitly declining to recognize a "de minimis" standard for digital sampling. The principle of "de minimis non curat lex" can be used as defense in India in cases of copyright infringement. The important issue is that whether de minimis principle could be used as separate defence than fair use under section 52 of Indian Copyright Act. In "India Tv Independent News Service Pvt. Ltd. and Ors. v Yashraj Films Pvt. Ltd.", the court discussed the applicability of "de mininims" principle at length. Before this case the position was not very clear with regard to the applicability. The facts of the case were that five words were copied from a song of five stanzas. After applying the five well-known factors commonly considered by courts in applying "de minimis", the court reached the conclusion that the infraction is trivial and attracts the defence of "de minimis". In "Endrew vs. Douglas County School District", the U.S. Supreme Court unanimously ruled, on March 22, 2017, that the Individuals with Disabilities Education Act (IDEA) requires more than "de minimis" efforts to provide equivalent educational opportunity to students with disabilities. The decision reversed a previous decision by the U.S. Court of Appeals for the Tenth Circuit. Following bus deregulation in Great Britain in 1986, small contracts for supplementary local bus services could be let by local authorities without competitive tendering. The Department for Transport's "Guidance on New De Minimis Rules for Bus Subsidy Contracts" (2005) notes that "The Transport Act 1985 (as amended by the 2000 Transport Act) introduced the provisions which govern the duties of local passenger transport authorities to secure local bus services where these would not otherwise be met. In the majority of cases these services have to be secured through competitive tender.