Law School Case Brief
Bikram's Yoga Coll. of India, Ltd. P'ship v. Evolation Yoga, Ltd. Liab. Co. - 803 F.3d 1032 (9th Cir. 2015)
A fundamental principle underlying constitutional and statutory copyright protection is the idea/expression dichotomy. Copyright protection is limited to the expression of ideas, and does not extend to the ideas themselves.
Plaintiff, Bikram Choudhury (Choudhury), developed a sequence of 26 yoga poses and two breathing exercises, arranged in a particular order, which he called the "Sequence." The "Sequence" was described in Choudhury's book entitled Bikram's Beginning Yoga Class, which was registered with the U.S. Copyright Office in 1979. In 1994, Choudhury introduced the "Bikram Yoga Teacher Training Course." In 2002 and 2005, respectively, Mark Drost and Zefea Samson enrolled in and successfully completed the three-month Bikram Yoga Teacher Training course. In 2009, Drost and Samson founded Evolation Yoga, LLC. Evolation Yoga offered several types and styles of yoga, including "hot yoga," which was similar to "Bikram's Basic Yoga System." Consequently, Choudhury and Bikram's Yoga College of India, L.P. filed a complaint against defendants Evolation Yoga, LLC, Mark Drost, and Zefea Samson (Evolation), alleging copyright infringement. The Evolation moved for partial summary judgment as to Choudhury's claim of copyright infringement of the "Sequence." The district court granted Evolation's motion, holding that the "Sequence" was a collection of facts and ideas not entitled to copyright protection.
Was the "Sequence" entitled to copyright protection?
The Court of Appeals for the Ninth Circuit held that the "Sequence," which was a sequence of yoga poses and breathing exercises developed Choudhury, was not a proper subject of copyright protection. Section 102(b) of the Copyright Act of 1976 expressly excluded the protection for any idea, procedure, process, system, method of operation, concept, principle, or discovery, regardless of the form in which it was described, explained, illustrated, or embodied in such work. The aforementioned section codified the "idea/expression dichotomy," under which every idea, theory, and fact in a copyrighted work would become instantly available for public exploitation at the moment of publication. The Court averred that under the idea/expression dichotomy, the "Sequence" was an idea, process, or system designed to improve health, and copyright protected only the expression of this idea, the words and pictures used to describe the sequence, and not the idea of the sequence itself. Since the "Sequence" fell squarely within Section 102(b)'s exclusions, the District Court properly granted Evolation's motion for partial summary judgment.
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