In German copyright law, the "Schöpfungshöhe" "(height of creation)" could classify copyrightable works into two classes, a design, or anything else (such as a literary work). While the threshold (which is reached even by simple creations, known as ""Kleine Münze"", German for "Small change") was low, the requirements for design, works that have a "purpose" (such as brand identification), was set much higher, as "novel" designs could be protected by the "lex specialis" law for design patents ("Geschmacksmustergesetz") or by trademark laws. Only design creations that were very high above the average were considered to be "works of applied art" and so granted copyright. As an example in case law, the logo of the German public broadcaster ARD, was considered ineligible for protection under German copyright law.