rural claimed a collection copyright in its directory. the court clarified that the intent of copyright law was not, as claimed by rural and some lower courts, to reward the efforts of persons collecting information—the so-called "sweat of the brow" or "industrious collection" doctrine—but rather "to promote the progress of science and useful arts" (u.s. const. art. i, § 8, cl. 8). that is, to encourage creative expression.