The idea-expression dichotomy as it stands envisages the freedom of the existence of ideas in the public domain as it involves dissemination of knowledge and therefore the encouragement of learning. This assertion has been seen to have been existing from the times of ancient Rome where Seneca had stated that ideas are common property and therefore cannot be protected  . In the case of Millar v. Taylor  wherein Judge Yates gave the dissenting opinion, stated clearly that the protection that was guaranteed under copyright laws was to print a set of intellectual ideas or modes of thinking or set of works. Therefore by not referring to a fixated material form the inevitable conclusion that forms is the fact that the dichotomy existed but as an abstraction. Another factor that is important to be seen is that there was the absence of patent law and therefore there would be no overlapping of rights of novelty or “idea” in such a case. This distinction that was created in a dissenting opinion was further diluted by the case of Emerson v. Davies  wherein it was stated precisely that there would be ‘copyright in a plan, arrangement and combination of materials for an author and in his mode of illustrating his subject if it is novel’. Therefore, the added criteria of novelty and the usage of words of arrangement and combination clearly dilutes the gap between idea and expression further. In the case of Lawrence v. Dana  the court said that the author of a book has as much right in the plan, arrangement and combination as he has in his thoughts sentiments and reflections. In this regard it is stated that there came a point in the history of copyright law wherein the dichotomy had been diluted and ideas were treated at par with expressions.