Massachusetts

Bleistein v. Donaldson Lithographing Co. in Massachusetts Law

How Bleistein v. Donaldson Lithographing Co. applies in Massachusetts: state-specific rules, key cases, and bar exam notes for Copyright.

State Approach

In Massachusetts, the principles established in Bleistein v. Donaldson Lithographing Co. have been influential in interpreting the originality requirement for copyright protection. The state generally adheres to the view that creativity, no matter how modest, qualifies for copyright under both state and federal law.

State Rule
In Massachusetts, a work must possess some degree of originality and creativity to be copyrightable, even if the creative expression is minimal, following the federal standard of originality under the Copyright Act.
Significant State Cases

Davis v. The Boston Herald, Inc.

The court held that a headline’s originality was sufficient to warrant copyright protection, affirming that even small creative choices can meet the threshold under Bleistein.

Salinger v. Colting

The court upheld that derivative works involving original elements could lead to copyright infringement, emphasizing the need to respect even modest contributions of creativity.

American Broadcasting Companies, Inc. v. Aereo, Inc.

The case addressed the reproduction right, confirming Massachusetts's alignment with federal standards on originality while considering the Bleistein precedent.

Comparison to Federal Law

Massachusetts law aligns closely with federal copyright standards, emphasizing the significance of originality as outlined in Bleistein. Both acknowledge that even minimal creativity suffices for copyright eligibility, reinforcing a broad interpretation of creative works.

Bar Exam Note

Understanding the implications of Bleistein in Massachusetts is crucial for the bar exam, especially in questions related to copyright law and originality requirements.

Practice Pointers
  • Always assess whether the work contains any original creative expression, however slight.
  • Consider recent Massachusetts cases that refer to Bleistein to understand how originality is interpreted in practice.
  • Be prepared to differentiate between pure factual works and those that exhibit minimal creativity in copyright disputes.

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