This article looks at the so-called "sweat of the brow" controversy in copyright law. While the US Supreme Court has resolved this controversy by explicitly denying copyright protection to the "sweat of the brow" involved in creating a compilation of facts, it is unclear how this matter will be resolved by the English courts. This article reviews the English cases on compilations of facts, examining how far the English courts have gone in their protection of such works under copyright law. This article also examines the implications of the "sweat of the brow" controversy on the protection of compilations of facts in electronic form, ie, computerized databases.