Copyright
499 U.S. 340 (U.S. Supreme Court 1991)
Study notes for Feist Publications, Inc. v. Rural Telephone Service Co., Inc.: professor notes, cold call prep, exam angles, and memory aids.
Compilation of facts lacks copyright protection unless it possesses originality in selection or arrangement.
The Supreme Court in Feist Publications v. Rural Telephone emphasized the importance of originality in copyright law. The ruling explicitly stated that mere compilations of facts without creativity do not meet the standard for copyright protection. This case is crucial in determining the boundaries of copyright, illustrating that while ideas and facts can be freely used, their original expression requires a level of creativity that was not present in Rural's directory. The decision serves as a benchmark for understanding what is considered 'origination' in the realm of factual compilations, especially in the context of telephone directories, databases, and similar works.
In addition, the Court's affirmance of the principle that facts themselves are not copyrightable informs future cases regarding data compilation. By indicating that the arrangement of those facts must contain an element of creativity to be eligible for protection, the ruling draws a significant line between what can be protected under copyright and what must remain in the public domain. This clarity has implications for future copyright disputes involving factual information across various sectors, like data services and publishing.
Facts Are Free, Originality Is Key
| Case | Distinction |
|---|---|
| Copyright Office v. Zachary | This case involved the protection of a creative work with original expression, unlike Feist's factual compilation. |
| National Basketball Ass'n v. Motorola, Inc. | In this case, real-time sports statistics were deemed protectable due to their arrangement and the creative aspect of delivery, contrasting Feist's purely factual approach. |
The ruling promotes the free use of facts and data, encouraging innovation and information sharing, which is essential in a knowledge-based economy.
Limiting copyright protection for factual compilations could disincentivize investment in data collection and curation, potentially harming smaller publishers and databases.
This case often appears on exams focusing on copyright law as a key example of the interpretation of originality and the copyright protection of factual information.