Durham, 630 F.2d at 911 (stating that a display of manufacturing skill is not independently enough to constitute originality). Indeed, the courts and commentators seem to agree that making decisions that enable one to reproduce or transform an already existing work into another medium or dimension — though perhaps quite difficult and intricate decisions — is not enough to constitute the contribution of something “recognizably his own.” See, e.g., Nimmer, § 2.08[C] at 2-111 (stating that the “mere act of converting two dimensions to three dimensions, although it creates a distinguishable variation, may not represent a contribution of independent effort because no one can claim to have independently evolved the idea and technique of working in three dimensions”); Durham, 630 F.2d at 911 (<HOLDING>); Gallery House, Inc. v. Yi, 582 F.Supp. 1294,
holding that the mere reproduction of the underlying characters in plastic even though  it undoubtedly involved some degree of manufacturing skill does not constitute originality holding that mere reprimand even if it does not result in actual dismissal can constitute adverse employment action holding that the mere passive extension of credit does not constitute any form of reliance holding that the mere failure to investigate does not constitute suppression of the evidence holding that probation does not constitute a sentence