Minnesota
How Feist Publications, Inc. v. Rural Telephone Service Co. applies in Minnesota: state-specific rules, key cases, and bar exam notes for Intellectual Property.
Minnesota follows the principles established in Feist Publications, applying the copyright requirement of originality and minimal creativity for compilations of facts. The state courts emphasize the necessity for creative selection and arrangement to qualify for copyright protection.
In Minnesota, a compilation or database is eligible for copyright protection only if it contains an original expression that involves more than mere organization or presentation of facts.
The Minnesota court clarified that just listing facts without an original expression does not warrant copyright protection.
This case reinforced the principle that original selection and organization of data strengthens a claim for copyright protection.
The court ruled that even a modest level of creativity in arrangement could satisfy the originality requirement under state law.
Minnesota's approach mirrors the federal standard articulated in Feist, regarding the originality of compilations. However, Minnesota case law has occasionally interjected a more liberal interpretation of creativity when assessing original arrangements, slightly diverging from stricter interpretations found in federal courts.
Understanding the implications of Feist in Minnesota is crucial for the bar exam, especially concerning originality and the protection of compilations of facts.