The "INS" decision recognized the doctrine of U.S. copyright law that there is no copyright in facts, which the Supreme Court later greatly elaborated in the "Feist" case in 1991, but nonetheless "INS" extended the prior law of unfair competition to cover an additional type of interference with business expectations: "misappropriation" of the product of "sweat of the brow." The case was decided during a period when a body of federal common law existed for business practices and torts, which the Supreme Court had power to declare or create, but two decades later the Supreme Court abolished that body of substantive law and held that state law must govern the field henceforth. Accordingly, the "INS" case no longer has precedential force, although state courts are free to follow its reasoning if they so choose.