Justia U.S. 9th Circuit Court of Appeals Opinion Summaries

Bikram’s Yoga College v. Evolation Yoga

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Plaintiffs filed suit against defendants, alleging, inter alia, that defendants infringed “Bikram’s Copyrighted Works through substantial use of Bikram’s Copyrighted Works in and as part of Defendants’ offering of yoga classes.” The district court granted defendants' motion for partial summary judgment as to the claim of copyright infringement of the "Sequence." The parties settled all remaining claims. At issue on appeal was whether a sequence of twenty-six yoga poses and two breathing exercises developed by Bikram Choudhury and described in his 1979 book, Bikram’s Beginning Yoga Class, is entitled to copyright protection. The court concluded that the Sequence is an idea, process, or system designed to improve health. Copyright protects only the expression of this idea - the words and pictures used to describe the Sequence - and not the idea of the Sequence itself. Because the Sequence is an unprotectible idea, it is also ineligible for copyright protection as a “compilation” or “choreographic work.” Therefore, the court concluded that the district court properly granted partial summary judgment in favor of defendants because the Sequence is not a proper subject of copyright. The court affirmed the judgment. View "Bikram's Yoga College v. Evolation Yoga" on Justia Law
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