Copyright and recipes in US

IP Spotlight published an interesting article regarding a lawsuit before the Federal court of Ohio, US.
The case concerns a dispute between co-owners of a restaurant who split their business. One of them was continuing to use recipes while the other owner pretended that he possess copyrights over them.
According to the court recipes are not protected by copyright at all because these represents only list ingredients.
For instance, recipes can be protected as trade secrets, know-how or ever by patents.
Copyright could protect recipe only if it is original and express creatively as well as copyright protects photographs attached  to them.
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