11.   These two cases, although subjected to criticism, seem to strengthen copyright protection notwithstanding that the look and feel test is not always easy to apply in practice.

12.   Even if copyright protection of computer programs is developed by the courts to become stronger, the Act does contain safeguards.

13.   In the United Kingdom, the question of copyright protection for an instruction set was considered in Microsense Systems Ltd. v Control Systems Technology Ltd..

14.   The threshold for copyright protection in the United Kingdom is low compared to some other countries.

15.   In some respects, the decision strengthens copyright protection for computer programs.

16.   Adoption of EC Commission proposals would only grant copyright protection to those databases which involved intellectual and creative effort in their compilation.

17.   The scope of the copyright protection, however, is not always clear.

18.   In the US, the copyright protection of databases is even more uncertain.

19.   Due to the legal uncertainty created by databases, the European Commission has recently published a proposed directive asserting and harmonising copyright protection of databases.

20.   Finally, copyright protection of electronic databases was considered, since legal protection for such databases is of critical importance for the continued growth of this market.