The court defined "author" to mean \"he to whom anything owes its origin; originator; maker.\" Burrow-Giles Lithographic Company v. Barony, 111 US. 53, 58 (1884). The originality requirement articulated in Burrow-Giles remains the touchstone of copyright protection today. Goldstein v. Cal., 412 1.1.5. 546, 56-62 (1973). It is the very \"premise of copyright law." Miller v. Universal studios, Inc., 650 F.2d 1365, 1368 (5 Cir. 1981). Leading scholars agree on this point. As one pair of commentators succinctly puts it, "The originality requirement is constitutionally mandated for all works." L. Ray Patterson and Craig Joyce, Monopolizing the Law: The Scope of Copyright Protection, 36 U.C.L.A. L. Rev. 719, 763 (1989). As professor Nimmer agrees, "Originality is a statutory as well as a constitutional requirement." Nimmer, supra 1.08, 1.09