In reaching this conclusion, we do not for a moment seek to downplay the considerable amount of time, effort, and skill that went into making Meshwerks' digital wire-frame models. But, in assessing the originality of a work for which copyright protection is sought, we look only at the final product, not the process, and the fact that intensive, skillful, and even creative labor is invested in the process of creating a product does not guarantee its copyrightability. See Feist, 499 U.S. at 359-60; Howard B. Abrams, Law of Copyright § 2:8 ("Even if the process is both expensive and intricate, an exact or near-exact duplicate of an original should not qualify for copyright.") (emphasis added); Wojcik, supra, 30 Hastings Comm. & Ent. L. J. at 267 ("This is not to say that [accurately reproducing an underlying image] requires no skill or effort; it simply means that such skill and effort does not suffice to invoke the highly advantageous legal monopoly granted under the Copyright Act."). In the case before us, there is no doubt that transposing the physical appearances of Toyota's vehicles from three dimensions to two, such that computer-screen images accurately reflect Toyota's products, was labor intensive and required a great amount of skill. But because
good law. In Feist, the Supreme Court specifically eschewed the notion that effort alone was enough to make the resultant work “original” and therefore the proper subject of copyright protection. See Feist, 499 U.S. at 359-60; see also supra note 9. Moreover, and as discussed in greater detail below, creative decision-making in the process is insufficient to render the product original. Cf. Nimmer on Copyright § 3.03[C][2] (stating that a district court erred in another case "in holding that the mere act of converting a public domain Santa Claus figure into a three-dimensional plastic form constituted sufficient originality").
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