In the first decision to recognize the “hot news” doctrine as applicable to online content, the U.S. District Court for the Southern District of New York denied a motion to dismiss filed by defendant All Headline News Corp. in a copyright infringement action brought by the Associated Press (Associated Press v. All Headline News Corp., 2009 WL 382690 (Feb. 17, 2009 S.D.N.Y.)). Contrasting the information collection and dissemination methods of plaintiff and defendant, the Court noted All Headline News Corp. pulled Associated Press’ on-line stories, and prepared them for republication, occasionally without altering the text. In finding that the AP had shown a cause of action for misappropriation, the court cited the landmark Supreme Court decision International New Service v. Associated Press, 248 U.S. 215 (1918), which held that breaking news is quasi-property subject to protection, quoting, “another [may not] endeavor to reap where it has not sown." Because the “hot news” doctrine will now apply to online content, purveyors of online news must be careful not to reap unauthorized rewards where other news organizations have sown.