Throughout 1998, the songs Carey was compiling songs for the compilation album led to a publicized conflict with Columbia Records. Carey insisted that while the compilation is not a greatest hits collection, Sony titled the album #1's to reflect the fact that the album is a collection of her number-one hits rather than her "greatest" or "favorite" songs. Carey has frequently cited "Underneath the Stars" (1996) and "Breakdown" (1998) as examples of songs she was unsuccessful in releasing on the collection. Carey has expressed distaste towards the album's song selection, expressing her disappointment in the omission of her "favorite songs."
