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I don't think that's true. You can create more elaborate works in less time thanks to technology, but you could sketch or compose a copyrightable work in minutes a century ago.

  There once was a property case
  which was wildly absurd on its face
  A camera, an ape
  and an unforeseen jape
  fell outside copyrightable space
^ 3 minutes of creative work. Refers to http://www.pri.org/stories/2014-08-07/internet-goes-ape-over...

Now this is not such a great thing that it deserves protection until 2084+my remaining lifespan, but my point is that verses of this sort could have been composed and committed to paper in 3 minutes in 1814 just as easily as in 2014.



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