17 U.S.C.S. § 4 provides: The works for which copyright may be secured under this title shall include all the writings of an author. 17 U.S.C.S. § 5 provides in part: The application for registration shall specify to which of the following classes the work in which copyright is claimed belongs: works of art; models or designs for works of art; reproductions of a work of art.
This case involves the validity of copyrights obtained by Stein et al. (Stein) for statuettes of male and female dancing figures made of semivitreous china. The controversy centered around the fact that although copyrighted as "works of art," the statuettes were intended for use and used as bases for table lamps, with electric wiring, sockets and lamp shades attached. The United States Court of Appeals for the Fourth Circuit that held that Stein had a valid copyright in statuettes it copyrighted as works of art and, subsequently, used as bases for table lamps it manufactured and sold. Mazer sought review of a judgment.
Can a lamp manufacturer copyright his lamp bases?
The Court affirmed the order declaring that the copyright was valid. The subsequent use of a copyrighted work of art in the manufacturing of lamps did not affect respondents' right to be protected against infringement of the work of art itself. Legislative history of the copyright act and the practice of the copyright agency showed that works of art and reproductions of works of art were intended by Congress to be copyrighted. The statuettes were original tangible expressions of an author's ideas. The reproduction of the statuettes as table lamp bases did not bar or invalidate the statuettes' registration. Nothing in the copyright statute supported the argument that the intended use of an article barred or invalidated registration. The Court also held that the use of a work of art as an element in a manufactured article was not a misuse of the copyright.