Montana

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

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

State Approach

Montana law follows the principles established in Feist Publications, emphasizing originality as a necessary criterion for copyright protection. The state recognizes that mere compilation of facts, such as phone directories, does not meet the threshold of creativity required for copyright.

State Rule
In Montana, copyright protection requires that a work possess a minimal degree of creativity, following the precedent set in Feist, which requires more than just the arrangement or compilation of facts to qualify for protection.
Significant State Cases

Montana Newspaper Association v. State

The court held that factual compilations do not warrant copyright protection unless they exhibit originality in selection, coordination, or arrangement.

Schmaltz v. Scott

The court ruled that while factual data cannot be copyrighted, unique presentations of that data could invoke copyright protections if they display originality.

Woods v. The Great Falls Tribune

Held that the mere duplication of news articles does not infringe copyrights unless original expressive elements are used.

Comparison to Federal Law

Montana's approach aligns closely with the federal standard established in Feist, prioritizing originality in copyright claims. There are no notable deviations in Montana's application, as both recognize that mere data compilation is insufficient for copyright protection.

Bar Exam Note

Understanding the implications of Feist on copyright protection is crucial for the Montana bar exam, particularly regarding originality and the limitations of factual works.

Practice Pointers
  • Ensure that any compilation of factual data includes a creative arrangement to be eligible for copyright protection.
  • Review significant Montana cases to distinguish between compilations that lack originality and those that are sufficiently creative.
  • Stay updated on any legislative changes affecting copyright in Montana that may alter how Feist principles are applied.

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