Works that are not sufficiently original, or which constitute facts, a method or process cannot enjoy copy protection.[18]. U.S. Courts do not recognize the "sweat of the brow" doctrine, which originally allowed protection for those who labored to collect and organize facts. To combat this, business which assemble databases of information have relied on contract law where copyright law offers no protection.[19] For a work to be original, it must possess a "modicum of creativity", which is a "low threshold" although some creativity must exist.