Landmark Copyright Infringement Cases
Landmark Copyright Infringement Cases
1. Baker v. Selden
Facts:
Baker copied a bookkeeping system described in a book written by Selden.
Selden had copyright over his book explaining the system.
Issue:
Whether copyright protection over the book extends to the underlying bookkeeping system (idea/method).
Holding:
The court ruled that copyright protects the expression in the book, not the underlying idea or system.
Baker could use the bookkeeping method freely, but could not copy the book’s exact expression.
Significance:
Established the idea-expression dichotomy in copyright law.
Only the specific expression is protected, not the idea, method, or system behind it.
2. Folsom v. Marsh
Facts:
The defendant copied several letters from the plaintiff’s collection into a new book.
Plaintiff claimed infringement of copyright.
Issue:
Whether copying parts of letters constituted infringement.
Holding:
The court recognized the original author’s exclusive right over their expression.
Fair use was considered, but unauthorized copying beyond allowed limits was infringement.
Significance:
One of the earliest discussions on the scope of copyright and fair use.
Emphasized protection of original expression.
3. Harper & Row Publishers, Inc. v. Nation Enterprises
Facts:
The Nation magazine published excerpts from President Ford’s unpublished memoir before its official release.
Harper & Row held copyright to the memoir.
Issue:
Whether unauthorized pre-publication excerpts constituted infringement.
Holding:
The court held that unauthorized copying of unpublished works violates copyright.
Highlighted the importance of protecting an author’s right to control first publication.
Significance:
Reinforced protection of unpublished works.
Emphasized the author's right to decide when and how work is published.
4. Rogers v. Koons
Facts:
Artist Jeff Koons created a sculpture closely resembling a photograph by Rogers.
Rogers sued for copyright infringement.
Issue:
Whether Koons’ sculpture was an infringement or a transformative use.
Holding:
Court found infringement as Koons’ work was substantially similar and not sufficiently transformative.
Copying protected expression, even in different mediums, is infringement.
Significance:
Confirmed that changing medium does not exempt infringement.
Protected artistic works across forms.
5. Oracle America, Inc. v. Google Inc.
Facts:
Google used parts of Oracle’s Java APIs in its Android operating system.
Oracle claimed copyright infringement.
Issue:
Whether APIs (functional software interfaces) are protected expression.
Holding:
The court held that certain software interfaces can be protected, but application of fair use and other doctrines is complex.
Significance:
Opened debate on software copyright.
Highlighted boundaries of copyright in computer software.
Key Principles from These Cases
| Principle | Explanation |
|---|---|
| Idea-Expression Dichotomy | Only expression is protected, not ideas or methods. |
| Originality and Substantial Similarity | Copying must be substantial and affect original expression. |
| Protection of Unpublished Works | Authors control first publication rights. |
| Medium Changes Don’t Avoid Infringement | Copying in different formats can still infringe. |
| Software Copyright Complexities | Interfaces and code have nuanced protections. |
Summary
Copyright law aims to protect the original expression of ideas to incentivize creativity while allowing free use of ideas themselves. Landmark cases have shaped this balance by:
Defining limits of protection.
Protecting authors’ rights.
Addressing new challenges with technology and art forms.
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