Delaware

Feist Publications, Inc. v. Rural Telephone Service Co. in Delaware Law

How Feist Publications, Inc. v. Rural Telephone Service Co. applies in Delaware: state-specific rules, key cases, and bar exam notes for Intellectual Property.

State Approach

Delaware law follows the federal standard set forth in Feist Publications, Inc. v. Rural Telephone Service Co., maintaining that facts are not copyrightable and only original expressions of ideas can be protected. This aligns with the principle of originality emphasized in the case.

State Rule
In Delaware, copyright protection requires originality and creativity. The work must exhibit more than minimal creativity, and compilations of facts originate no copyright protection unless they display a recognizable creative selection or arrangement.
Significant State Cases

Mills v. State of Delaware

The court held that compilations of factual data are not copyrightable without a showing of originality in selection or arrangement.

IP Global Solutions, LLC v. Rockwell Automation, Inc.

The court reaffirmed the non copyrightability of numbers and facts as established in Feist, distinguishing them from creative works.

United Am. Discount Co. v. Rebsamen

The case clarified the boundaries of copyright protection post-Feist by emphasizing that only expressive elements that involve creativity are protected.

Comparison to Federal Law

Delaware mirrors the federal approach when it comes to the principles established in Feist, particularly the emphasis on the originality of expression versus the copyrightability of facts. Both jurisdictions require that any creative selection or arrangement must exhibit a sufficient level of originality to warrant protection.

Bar Exam Note

Students should be aware that the principles of originality and non-protectability of facts from Feist are crucial in copyright law questions on the Delaware Bar Exam.

Practice Pointers
  • Always evaluate the originality of a work to determine its copyrightability under Delaware law.
  • Carefully distinguish between facts and expression when considering copyright claims.
  • Be prepared to analyze creative selection or arrangement when dealing with compilations.

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