It's my understanding that "sweat of the brown" does not create a copyright at all. That was the entire argument behind the claim that phonebooks had no copyright protection. Similarly pure indexes have no copyright protection since they exhibit no creativity at all. Bad news for indexers. In a message dated 4/25/2011 10:58:23 P.M. Pacific Daylight Time, thomas.dalton(a)gmail.com writes: I would expect that to vary from jurisdiction to jurisdiction. For example, jurisdictions that includes some kind of "sweat of the brow" doctrine would probably protect translations. What jurisdiction are you referring to?