Computer programs and code can be copyrightable when authored by a human, although courts look at originality and various aspects of the program such as the structure, sequence, and organization. See The Computer Software Act of 1980 (that amended § 101 of the 1976 Act); Apple Computer, Inc. v. Franklin Computer Corp., 714 F.2d 1240 (3d Cir. 1983), cert. dismissed, 464 U.S. 1033 (1984).[12] Id., citing Eldred v. Ashcroft, 537 U.S. 186, 212 (2003).