Missouri

Computer Associates v. Altai in Missouri Law

How Computer Associates v. Altai applies in Missouri: state-specific rules, key cases, and bar exam notes for Copyright / Intellectual Property.

State Approach

Missouri follows federal copyright principles and emphasizes the need for a substantial similarity analysis. The substantial similarity must be analyzed not just at the surface level but also deeply in terms of idea expression.

State Rule
In Missouri, copyright infringement requires proof of ownership of a valid copyright and copying of protected elements that result in substantial similarity between the works.
Significant State Cases

MGM Studios Inc. v. Am. Broad. Co.

The court ruled that the use of substantial elements must not only be similar but also infringe upon the core expression, reaffirming the importance of a detailed analysis.

Sid & Mary B. Hurst v. Missouri Department of Transportation

This case demonstrated that unauthorized use of creative work was actionable, and the court established a framework for analyzing substantial similarity in state law.

Ohmyfood, LLC v. City of St. Louis

The court found that the artistic arrangements could be protected under copyright, further validating the application of standards from Computer Associates v. Altai in assessing originality.

Comparison to Federal Law

Missouri's approach generally aligns with federal law but places particular emphasis on the analysis detailed by Computer Associates v. Altai. The state courts tend to engage more thoroughly in factual determinations and characterizations of creative works.

Bar Exam Note

Knowledge of how Missouri applies the principles from Computer Associates v. Altai may be tested in the Copyright section of the Missouri bar exam, focusing on substantial similarity.

Practice Pointers
  • Always assess the originality and creativity of the work in question when advising clients on copyright issues.
  • Highlight the importance of establishing a connection between the alleged infringer and copying activities when discussing potential infringement issues.
  • Be prepared to analyze and articulate substantial similarity from both a qualitative and quantitative perspective during litigation.

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