In the English decision of Donoghue v. Allied Newspapers Limited (1938) Ch 106, the court illustrated the concept by stating that "the person who has clothed the idea in form, whether by means of a picture, a play or a book" owns the copyright.
在英国的法院判决中，Donoghue v. Allied Newspapers Limited (1938) Ch 106 对该区分进行了如下表述：“对一个概念用任何形式的表述，不管是图像、戏剧还是书籍”，都能获得该表述的著作权。