diff --git a/gpl-lgpl.tex b/gpl-lgpl.tex
index 1e2feb1ed5c0a0fbeefa75eda7339dc0d0bc5790..1603e583b76a880dd5a679ed91622f9af1eaf9ee 100644
--- a/gpl-lgpl.tex
+++ b/gpl-lgpl.tex
@@ -30,6 +30,7 @@
 \begin{tabbing}
 Copyright \= \copyright{} 2003, 2004, 2005, 2006 \= \hspace{.2in} Free Software Foundation, Inc. \\
 Copyright \= \copyright{} 2014 \= \hspace{.2in} Bradley M. Kuhn \\
+Copyright \= \copyright{} 2014 \= \hspace{.2in} Anthony K. Sebro, Jr. \\
 \end{tabbing}
 
 Authors of \tutorialpartsplit{``Detailed Analysis of the GNU GPL and Related Licenses''}{this part} are: \\
@@ -38,6 +39,7 @@ Free Software Foundation, Inc. \\
 Bradley M. Kuhn \\
 David ``Novalis'' Turner \\
 Daniel B. Ravicher \\
+Tony Sebro \\
 John Sullivan
 
 \vspace{.3in}
@@ -1172,7 +1174,7 @@ F.2d 693 (2nd Cir. 1992); Engineering Dynamics, Inc. v. Structural
 Software, Inc., 26 F.3d 1335 (5th Cir. 1994); Kepner-Tregoe,
 Inc. v. Leadership Software, Inc., 12 F.3d 527 (5th Cir. 1994); Gates
 Rubber Co. v. Bando Chem. Indust., Ltd., 9 F.3d 823 (10th Cir. 1993);
-Mitel, Inc. v. Iqtel, Inc., 124 F.3d 1366 (10th Cir. 1997); 5 Bateman
+Mitel, Inc. v. Iqtel, Inc., 124 F.3d 1366 (10th Cir. 1997); Bateman
 v. Mnemonics, Inc., 79 F.3d 1532 (11th Cir. 1996); and, Mitek Holdings,
 Inc. v. Arce Engineering Co., Inc., 89 F.3d 1548 (11th Cir. 1996).
 
@@ -1337,22 +1339,26 @@ identical in order to be held a derivative work of an original, while
 
 \section{No Protection for ``Methods of Operation''}
 
-The First Circuit expressly rejected the AFC test and, instead, takes a
-much narrower view of the meaning of derivative work for software. The
-First Circuit holds that ``method of operation,'' as used in \S~102(b) of
+The First Circuit has taken the position that the AFC test is inapplicable 
+when the works in question relate to unprotectable elements set forth in 
+\S 102(b).  Their approach results in a much narrower definition
+of derivative work for software in comparison to other circuits. Specifically, 
+the
+First Circuit holds that ``method of operation,'' as used in \S 102(b) of
 the Copyright Act, refers to the means by which users operate
 computers. Lotus Development Corp. v. Borland Intl., Inc., 49 F.3d 807
-(1st Cir. 1995). More specifically, the court held that a menu command
+(1st Cir. 1995).  In Lotus, the court held that a menu command
 hierarchy for a computer program was uncopyrightable because it did not
 merely explain and present the programs functional capabilities to the
 user, but also served as a method by which the program was operated and
 controlled. As a result, under the First Circuits test, literal copying
 of a menu command hierarchy, or any other ``method of operation,'' cannot
 form the basis for a determination that one work is a derivative of
-another. It is also reasonable to expect that the First Circuit will read
-the unprotectable elements set forth in \S~102(b) broadly, and, as such,
-promulgate a definition of derivative work that is much narrower than that
-which exists under the AFC test.
+another.  As a result, courts in the First Circuit that apply the AFC test
+do so only after applying a broad interpretation of \S 102(b) to filter out
+unprotected elements. E.g., Real View, LLC v. 20-20 Technologies, Inc., 
+683 F. Supp.2d 147, 154 (D. Mass. 2010).
+
 
 \section{No Test Yet Adopted}
 
@@ -1395,16 +1401,24 @@ the organizational charts of the two programs was not substantial enough
 to support a finding of infringement because they were too simple and
 obvious to contain any original expression.
 
-Perhaps not surprisingly, there have been few cases involving a highly
+In the case of Oracle America v. Google, 872 F. Supp.2d 974 (N.D. Cal. 2012),
+the Northern District of California District Court examined the question of 
+whether the application program interfaces (APIs) associated with the Java
+programming language are entitled to copyright protection.  While the 
+court expressly declined to rule whether all APIs are free to use without 
+license (872 F. Supp.2nd 974 at 1002), the court held that the command 
+structure and taxonomy of the APIs were not protectable under copyright law.
+Specifically, the court characterized the command structure and taxonomy as
+both a ``method of operation'' (using an approach not dissimilar to the 
+First Circuit's analysis in Lotus) and a ``functional requirement for 
+compatability'' (using Sega v. Accolade, 977 F.2d 1510 (9th Cir. 1992) and
+Sony Computer Ent. v. Connectix, 203 F.3d 596 (9th Cir. 2000) as analogies),
+and thus unprotectable subject matter under \S 102(b).  
+
+Perhaps not surprisingly, there have been few other cases involving a highly
 detailed software derivative work analysis. Most often, cases involve
 clearer basis for decision, including frequent bad faith on the part of
-the defendant or overaggressiveness on the part of the plaintiff.
-However, no cases involving Free Software licensing have ever gone to
-court. As Free Software becomes an ever-increasingly important part of
-the economy, it remains to be seen if battle lines will be
-drawn over whether particular programs infringe the rights of Free
-Software developers or whether the entire community, including industry,
-adopts norms avoiding such risk.
+the defendant or overaggressiveness on the part of the plaintiff.  
 
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