Believing That He Was a Very Creative Person,and Knowing He

Believing that he was a very creative person,and knowing he was broke,Sam decided he would attempt to sell some of the songs he continually created.He mostly just whistles his new tunes,but he now wants them to be protected by copyright.Which of the following is not a requirement for copyright protection?

A) The idea on which Sam's songs are based must be original.
B) Sam's songs must be original and not a copy of someone else's work.
C) Sam's songs must be put in some material form.
D) Sam has to satisfy a citizenship or residence requirement.
E) Sam's songs must fall into one of the specified categories of work protected by the Copyright Act (e.g.,literary,dramatic) .