11. ArbCom has previously used a rule that substantial similarity is enough in this case & mdash; is it? 12. Confusion arises because some courts use " substantial similarity " in two different contexts during a copyright infringement case. 13. A Washington University professor, an expert in comparative literature, testified that there were substantial similarities between the works. 14. Paraphrasing rises to the level of copyright infringement when there is substantial similarity between an article and a copyrighted source. 15. The intrinsic test would decide whether an " ordinary reasonable person " would consider there were substantial similarities in expression. 16. The number of mitochondria in a cell can vary widely by organism, genome that shows substantial similarity to bacterial genomes. 17. Because the idea and expression are inseparable, the court found that there was no substantial similarity and no copyright infringement. 18. Demonstrating substantial similarity can be difficult when the two works are not exact replicas, either in full or in part. 19. But Judge John Bissell found " no substantial similarity between the dollies " after analyzing more than 122 of their elements. 20. Only when a work rises to a level of " substantial similarity " does it infringe to the point of being legally actionable.
