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Baker v. Selden doctrine is a principle that holds that if an idea can only be expressed in one or a small number of ways, copyright law will not protect the expression because it has "merged" with the idea. As an idea cannot be copyrighted, neither can an expression that must inevitably be used in order to express the idea. When the idea and expression are very difficult to separate, they are said to merge. Baker v. Selden, 101 U.S. 99 (U.S. 1880) is the seminal case addressing the distinction between the treatment of an idea verses the expression of an idea. In this case the plaintiff sought to have accounting forms he created covered by the copyright protection he obtained for a book he wrote in which he explained a method of book-keeping that he had developed. The Supreme Court concluded that the protection the plaintiff was afforded for his book, which described the accounting system idea, would not cover the forms, which proved to be the tangible manifestation of his idea. The Court's rationale is also known as the merger doctrine.