un-protectable because they are either insufficiently independent or insufficiently creative or both, see 1 William F. Patry, Copyright Law and Practice 333 (1994), but it does not make sense to state categorically that no combination of numbers or words short enough to be deemed a “phrase” can possess “as least some minimal degree of creativity.” Feist, 499 U.S. at 345, 111 S.Ct. 1282. In fact, the plain language of the regulation does not lend itself to such a construction. Section 202.1(a) states that “short phrases such as names, titles, and slogans” are not copyrightable. Thus, other short expressions dissimilar to names, titles, or slogans are not covered by the regulation. See Applied Innovations, Inc. v. Regents of University of Minnesota, 876 F.2d 626, 636 (8th Cir.1989) (<HOLDING>). Therefore, “it would seem (notwithstanding
holding that statements at issue were protected expressions of opinion because they lacked specificity and precision and the factual implications concerning such statements were unclear holding that test statements were not short phrases under  2021 because they were not titles names or slogans holding that although miranda warnings were not given to defendant police officers they had no cause of action under 42 usc  1983 because they were never prosecuted holding that statements downplaying internal control problems were actionable because they misled investors into believing the problems were not as serious or extensive as they were holding that statements made in the course of negotiation were not contracts and such statements were merged into the final written agreement