Oh, you mean this? "Originality remains the sine qua non of copyright; accordingly, copyright protection may extend only to those components of a work that are original to the author." The article does state that the author must show a "modicum of creativity," but it never defines creativity to any extent that I saw used in this case. Besides, Java obviously fulfilled all requirements.
Now I know your arguing specifically about the 9 lines of code, but I still see nothing that says this is the reason Google won. Google admitted to copying the code, stating it was negligible and already removed. The Jury decided Google infringed with those nine lines forcing Oracle to pretty much admit the lines had no monetary value. The judge ruled in Google's favor, his logic: "The idea that someone would copy that when they could do it themselves just as fast, it was an accident. There’s no way you could say that was speeding them along to the marketplace. You’re one of the best lawyers in America, how could you even make that kind of argument?" Originality/creativity were never really the point.