List of copyright case law
From Wikipedia, the free encyclopedia
The following is a list of cases that deal with issues of concern to copyright in various jurisdictions. Some of these cases are leading English cases as the law of copyright in various Commonwealth jurisdictions developed out of English law while these countries were colonies of the British Empire. Other cases provide background in areas of copyright law that may be of interest for the legal reasoning or the conclusions they reach.
Contents |
[edit] Australia
- Victoria Park Racing and Recreation Grounds Co. Ltd v. Taylor (1937) 58 CLR 479 idea-expression divide
- Cuisenaire v. Reed [1963] VR 719 (a literary work cannot be infringed by a three-dimensional reproduction)
- Pacific Film Laboratories v. Commissioner of Tax (1970) 121 CLR 154 [negative right definition]
- Elanco v. Mandops (1979) FSR 46 (instructions on herbicide are a literary device)
- Zeccola v. Universal City Studios Inc. (1982) 46 ALR 189: there is no copyright in the idea of a theme or a story, but there may be a time where a combination of events and characters reaches sufficient complexity as to give rise to dramatic work copyright
- Computer Edge Pty Ltd v. Apple Computer Inc (1986) 161 CLR 171 (test in Exxon for literary work is "not intended to establish a comprehensive or exhasutive definition of literary work for copyright purposes" per Mason and Wilson JJ)
- CBS Records v. Gross (1989) 15 IPR 385 (a cover version of a song can be an original work itself capable of copyright protection)
- Greenfield Products Pty Ltd v. Rover-Scott Bonnar Ltd (1990) 17 IPR 417 per Pincus J, what is not a sculpture
- Autodesk v. Dyason (No.2) (1993) 111 ALR 385 (the idea-expression divide is the "dominant principle in copyright law" per Mason CJ: "when the expression of any idea is inseparable from its function, it forms part of the idea and is not entitled to the protection of copyright" per Dawson J)
- Sega Enterprises Ltd v. Galaxy Electronics Pty Ltd 35 IPR 161 (1997): interactive video games involving computer images fall in the definition of cinematograph film
[edit] Canada
- Muzak Corp. v. CAPAC [1953] 2 S.C.R. 45 Authorization as infringement.
- Canadian Admiral Corp. v. Rediffusion Inc. [1954] Ex. C.R. 382 performance in public
- Cuisenaire v. South West Imports Ltd. [1968] 1 Ex C.R. 493
- Snow v. The Eaton Centre Ltd. (1982) 70 C.P.R. (2d) 105 (Ont. H.C.): moral rights
- Apple Computer Inc. v. Mackintosh Computers Ltd. [1987] copyright in computer programs
- DRG Inc. v. Datafile Ltd. (1987), 18 C.P.R. (3d) 538
- Yumbulul v. Reserve Bank of Australia (1991) 21 IPR 481: "copyright law does not provide adequate protection of Aboriginal community claims to regulate the reproduction and use of works which are essentially communal in origin"
- Prise de Parole Inc. v. Guerin [1995] F.C.J. No. 1583: Moral rights
- Gould Estate v. Stoddart Publishing Co. Ltd. (1996), 74 C.P.R. (3d) 206
- Delrina Corp. v. Triolet Systems Inc. (2002) Ontario
- Théberge v. Galerie d'Art du Petit Champlain Inc. [2002] 2 S.C.R. 336 Canadian definition of "reproduction".
- Robertson v. Thomson Corp. (2004) Ont. CA republication of collective works in electronic databases
- CCH Canadian Ltd. v. Law Society of Upper Canada 2004 SCC 13 (established that setting up the facilities that allow copying does not amount to authorizing infringement)
- Society of Composers, Authors and Music Publishers of Canada v. Canadian Association of Internet Providers 2004 SCC 45 (ISPs as common carriers. Status of caches)
- BMG Canada Inc. v. Doe 2005 FCA 193 (privacy rights of filesharers)
[edit] France
- Societe Le Chant du Monde v. Societe Fox Europe and Societe Fox Americaine Twentieth Century Cour d'appel, Paris, Jan. 13, 1953, D.A. 1954, 16, 80, held in favor of the plaintiffs due to the very strong moral rights regime in France.
[edit] New Zealand
- Green v. Broadcasting Corp of NZ (1989) APIC 90-590: Privy Council definition of "dramatic works": " a dramatic work must have sufficient unity to be capable of performance"
[edit] United Kingdom
- Millar v. Taylor (1769) 4 Burr 2303; 98 ER 201 (copyright is a form of property)
- Donaldson v. Beckett (1774) 4 Burr 2408; 98 ER 257 (copyright is not perpetual)
- Dick v. Yates (1881) 18 Ch D 76: a title is not long enough to consistute a literary work
- Kenrick v. Lawrence (1890) L.R. QBD 99
- Hollingrake v. Truswell [1894] Ch. 420
- Walter v. Lane (1900) AC 539 ("reporter's copyright")
- Corelli v. Grey (1913) 29 TLR 570 (four reasons for clear objective similarity between works)
- University of London Press Ltd. v. University Tutorial Press Ltd. [1916] 2 Ch. 601
- Re Dickens (1934) 1 Ch 267
- Hawkes & Son (London) Ltd v. Paramount Film Service Ltd [1934] 1 Ch 593: the Colonel Bogey case - infringement of copyright occurs when "a substantial, a vital and an essential part" of a work is copied, per Lord Slesser
- Jennings v. Stephens [1936] Ch. 469 "performance in public" as infringement.
- Donahue v. Allied Newspapers Ltd (1938) Ch 106 [ "idea-expression divide"]
- Ladbroke (Football) Ltd v. William Hill (Football) Ltd [1964]1 WLR 273
- LB (Plastics) Ltd v. Swish Products Ltd [1979] RPC 551 (the basis of copyright protection is that "one man must not be able to appropriate the result of another's labour")
- Exxon Corp v. Exxon Insurance Consultants International (1981) 3 All ER 241 [Exxon name has no copyright]
- Express Newspapers v. News (UK) Ltd (1990) 18 IPR 201 (confirming Walter v. Lane)
[edit] United States
Note: if no court name is given, according to convention, the case is from the Supreme Court of the United States. Supreme Court rulings are binding precedent across the United States; Circuit Court rulings are binding within a certain portion of it (the circuit in question); District Court rulings are not binding precedent, but may still be referred to by other courts.
Case name | Reporter | Court/year | Subject, important findings |
---|---|---|---|
Wheaton v. Peters | 33 U.S. (8 Pet.) 591 | 1834 | There is no such thing as common law copyright and one must observe the formalities to secure a copyright. |
Baker v. Selden | 101 U.S. 99 | 1879 | Idea-expression divide. |
Burrow-Giles Lithographic Co. v. Sarony | 111 U.S. 53 | 1884 | Extended copyright protection to photography. |
Bobbs-Merrill Co v. Straus | 210 U.S. 339 | 1908 | No license to use copyrighted material. License cannot extend holder's rights beyond statute defined by Congress. |
Bauer & Cie. v. O'Donnell | 229 U.S. 1 | 1913 | Differences between patent and copyright defined also prohibits a license from extending holder's rights beyond statute. |
Macmillan Co. v. King | 223 F. 862 | D.Mass. 1914 | Limits of fair use with respect to an educational context and to summaries. |
Nichols v. Universal Pictures Co. | 45 F.2d 119 | 2d Cir. 1930 | No copyright for "stock characters". |
Shostakovich v. Twentieth Century-Fox Film Corp. | 196 Misc. 67, 80 N.Y.S.2d 575 (N.Y. Sup. Ct. 1948), aff'd 275 A.D. 692, 87 N.Y.S.2d 430 (1949) | 1948–9 | No moral rights in public domain works. |
National Comics Publications v. Fawcett Publications | 191 F.2d 594 (1951), clarified 198 F.2d 927 (1952) | 2d Cir. 1951–2 | Derivative works; an author does not forfeit his copyright to a piece of intellectual property if his work is contracted to another who fails to properly copyright works which incorporate the original property (obsoleted by Copyright Act of 1976). |
Irving Berlin et al. v. E.C. Publications, Inc. | 329 F. 2d 541 | 2d. Cir. 1964 | Parody. |
Williams & Wilkins Co. v. United States | 487 F.2d 1345 | Ct. Cl. 1973 | Libraries' photocopying for research was fair use. |
Stern Electronics, Inc. v. Kaufman | 669 F.2d 852 | 2d Cir. 1982 | Copyright on computer programs includes images and sounds as well as the computer code. |
Apple Computer, Inc. v. Franklin Computer Corp. | 714 F.2d 1240 | 3rd Cir. 1983 | Computer software is protected by copyright (affirmed and obsoleted by subsequent legislation). |
Sony Corp. of America v. Universal City Studios, Inc. (the "Betamax case") | 464 U.S. 417 | 1984 | Products with substantial non-infringing uses (video recorders) may be sold even if they can be used illicitly. |
Dowling v. United States | 473 U.S. 207 | 1985 | Copyright infringement is not theft, conversion, or fraud; illegally-made copies are not stolen goods. |
Harper & Row v. Nation Enterprises | 471 U.S. 539 | 1985 | The interest served by republication of a public figure's account of an event is not sufficient to permit nontransformative fair use. |
Fisher v. Dees | 794 F.2d 432 | 9th Cir. 1986 | Parody of song performance is legitimate fair use |
Steinberg v. Columbia Pictures Industries, Inc. | 663 F. Supp. 706 | S.D.N.Y. 1987 | Derivative works. |
Anderson v. Stallone | 11 USPQ2D 1161 | C.D. Cal 1989 | Derivative works. |
Community for Creative Non-Violence v. Reid | 490 U.S. 730 | 1989 | Works for hire. |
Basic Books, Inc. v. Kinko's Graphics Corporation | 758 F. Supp. 1522 | S.D.N.Y. 1991 | Articles copied for educational use are not necessarily fair use. |
Advent Sys. Ltd. v. Unisys Corp | 925 F.2d 670, 675-76 | 3d Cir. 1991 | The sale of software is the sale of a good within the meaning of the Uniform Commercial Code. |
Downriver Internists v. Harris Corp | 929 F.2d 1147, 1150 | 6th Cir. 1991 | The sale of software is the sale of a good within the meaning of the Uniform Commercial Code. |
Feist Publications v. Rural Telephone Service | 499 U.S. 340 | 1991 | "Sweat of the brow" alone is not sufficient to bestow copyright. |
Grand Upright Music, Ltd. v. Warner Bros. Records, Inc. | 780 F. Supp. 182 | SDNY 1991 | Music sampling is generally copyright infringement. |
Step-Saver Data Systems, Inc. v. Wyse Technology | 939 F.2d 91 | 3rd Cir. 1991 | The need to characterize the transaction as a license to use software is "largely anachronistic.". |
Computer Associates Int. Inc. v. Altai Inc. | 982 F.2d 693 | 2d Cir. 1992 | "Substantial similarity" is required for copyright infringement to occur. |
Lewis Galoob Toys, Inc. v. Nintendo of America, Inc. | 780 F. Supp. 1283 | 9th Cir. 1992 | Consumers may modify purchased computer games for their own use. |
Rogers v. Koons | 960 F.2d 301 | 2d Cir. 1992 | Fair use and parody. |
MAI Systems Corp. v. Peak Computer, Inc. | 991 F.2d 511 | 9th Cir. 1993 | RAM ("working memory") copies of computer programs are governed by copyright. |
Apple Computer, Inc. v. Microsoft Corp. | 35 F.3d 1435 | 9th Cir. 1994 | Certain components of computer programs' graphical user interfaces are not copyrightable. |
Campbell v. Acuff-Rose Music, Inc. | 510 U.S. 569 | 1994 | Commercial parody can be fair use. |
Carter v. Helmsley-Spear Inc. | 861 F. Supp. 303 | S.D.N.Y., 1994 | Interpreting moral rights provisions of U.S. Visual Artists Rights Act (overturned for other reasons: 71 F.3d 77 (2d Cir. 1995), cert. denied 116 S. Ct. 1824 (1996)). |
Lotus v. Borland | 49 F.3d 807 | 1st Cir. 1995 | Software interfaces per se are "methods of operation" and are not covered by copyright. |
Self-Realization Fellowship Church v. Ananda Church | 59 F.3d 902, 910 | 9th Cir. 1995 | Renewal rights are not assignable. |
Applied Info. Mgmt., Inc, v. Icart | 976 Supp. 149, 155 | E.D.N.Y. 1997 | The sale of software is the sale of a good. Case was dropped. |
Itar-Tass Russian News Agency v. Russian Kurier, Inc. | 153 F.3d 82 | 2d Cir. 1998 | Jurisdiction with closest association to putative owner applies to determine copyright ownership. |
Bridgeman Art Library Ltd. v. Corel Corporation | 36 F. Supp. 2d 191 | S.D.N.Y. 1999 | "Slavish copying" is inherently uncreative and cannot confer copyright. |
Estate of Martin Luther King, Jr., Inc. v. CBS, Inc. | 194 F.3d 1211 | 11th Cir. 1999 | Giving a public speech is not public-domain publication under the 1909 Copyright Act. |
Novell, Inc. v. CPU Distrib., Inc. | 2000 US Dist. Lexis. 9975 | SD Tex. 2000 | The first-sale doctrine applies to software. |
UMG v. MP3.com | 2000 U.S. Dist. LEXIS 5761 | S.D.N.Y. 2000 | Distribution of copyrighted music without permission of the copyright holders is infringement even if the downloader already owns a copy of the music. |
A & M Records, Inc. v. Napster, Inc. | 239 F.3d 1004 | 9th Cir. 2001 | Knowingly failing to take steps to prevent infringement, while benefiting from said infringement, is grounds for contributory infringement. Also, users of file-sharing services infringe by both uploading and downloading works without permission. |
New York Times Company v. Tasini | 533 U.S. 483 | 2001 | Freelance journalists did not grant electronic republication rights for collective work. |
SoftMan Products Co. v. Adobe Systems Inc. | CV 00-04161 DDP (AJWx) | C.D.C.A. 2001 | The first-sale doctrine applies to software and cannot be waived or taken away through an end-user license agreement. |
Suntrust v. Houghton Mifflin | 252 F. 3d 1165 | 11th Cir. 2001 | Parody and fair use. |
Universal v. Reimerdes | 273 F.3d 429 | 2d Cir. 2001 | Affirmed the anti-circumvention provisions of the Digital Millennium Copyright Act. |
Veeck v. Southern Bldg. Code Cong. Int'l | 241 F.3d 398, 416 | 5th Cir. 2001 | A private organization cannot assert copyright protection for its model codes, after the models have been adopted by a legislative body and become the law. |
Kelly v. Arriba Soft Corporation | 280 F.3d 934 | 3d Cir. 2002 | Thumbnails and inline linking can be fair use. |
Dastar Corp. v. Twentieth Century Fox Film Corp. | 539 U.S. 23 | 2003 | Trademark cannot preserve rights to a public domain work. |
Eldred v. Ashcroft | 537 U.S. 186 | 2003 | Congress may retroactively extend the duration of works still under copyright, as long as the extension is limited. |
CoStar Group v. LoopNet | 373 F.3d 544 | 4th Cir. 2004 | Internet service provider was found liable for copyright infringement of photographs of commercial real estate by allowing subscribers to post the photographs on the provider's website. |
Arizona Cartridge Remanufacturers Association Inc. v. Lexmark International Inc. | 03-16987 D.C. No. CV-01-04626SBA/JL OPINION | 9th Cir. 2005 | End User License Agreements on a physical box can be binding on consumers who signal their acceptance of the license agreement by opening the box. |
Golan v. Gonzales | No. 01-B-1854, 2005 U.S. Dist. LEXIS 6800 | D.Co. 2005 | Congress may retroactively restore copyright in works that have fallen into the public domain (a contrary principle in patent case law being held inapplicable to copyright). |
MGM Studios, Inc. v. Grokster, Ltd. | 545 U.S., 125 S. Ct. 2764 | 2005 | Distributors of peer-to-peer file-sharing software can be liable for copyright infringement if there are "affirmative steps taken to foster infringement". |
Perfect 10 v. Google Inc | CASE NO. CV 04-9484 AHM (SHx) | CDCA 2006 | Thumbnails in Web searches were fair use. Framed inline images of full size were not infringing copies. (9th circuit reversed the DC's holding of no Fair Use) |