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For the next few years most, but not all, circuit courts accepted the Whelan decision on SSO in one form or another.{{sfn|Kappel|1991|p=705}}
In one case a court found that a defendant had infringed the right to prepare a derivative work when they copied the sequence, structure, and organization of the plaintiff's file formats, screen, reports, and transaction codes, even though different data fields were present.{{sfn|Stapleton|2002|p=9.6}}
In
In the 1990 case of Lotus v. Paperback the U.S. District Court for Massachusetts decided that Paperback's VP-Planner software violated the copyright of Lotus's 1-2-3 spreadsheet program since it had the same user interface, even though the underlying code was completely different.{{sfn|Davidson|1997|p=115}}
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