Narrative Opinion Summary
The case involves a dispute between a certified public utility in Kansas, Rural Telephone Service Company, and Feist Publications, a company producing larger area-wide directories. Feist sought to license Rural's white pages but was denied, prompting Feist to extract subscriber listings without permission, resulting in a copyright infringement lawsuit initiated by Rural. The District Court ruled in favor of Rural, supported by the Tenth Circuit Court of Appeals, asserting the copyrightability of telephone directories. However, the Supreme Court reversed this decision, focusing on the requirement of originality as a prerequisite for copyright protection. The Court clarified that while facts themselves are unprotectable, a compilation may be eligible for copyright if it demonstrates originality in its selection and arrangement. Rural's white pages, listing subscriber information alphabetically, failed to meet this minimal creativity standard. The decision rejected the 'sweat of the brow' doctrine, underscoring that labor alone does not confer copyright. Consequently, Feist's use of Rural's listings did not constitute infringement, as the directory's arrangement lacked the requisite originality for protection under the Copyright Act of 1976.
Legal Issues Addressed
Copyrightability of Factual Compilationssubscribe to see similar legal issues
Application: Rural's arrangement of subscriber listings in alphabetical order did not meet the minimal creativity standard necessary for copyright protection.
Reasoning: Rural Telephone Service Company, Inc. publishes a telephone directory in compliance with state law, listing subscribers' names, towns, and telephone numbers in alphabetical order. This arrangement lacks the creativity necessary for copyright protection...
Distinction Between Facts and Original Expressionsubscribe to see similar legal issues
Application: Facts themselves remain unprotected, while only the original selection or arrangement of facts may be eligible for copyright protection.
Reasoning: Facts, by nature, lack authorship and therefore are not copyrightable. While a compilation of facts can be eligible for copyright if it exhibits originality through selection and arrangement, the protection only extends to the author's original contributions, not the underlying facts themselves.
Originality in Copyright Lawsubscribe to see similar legal issues
Application: The Supreme Court held that the white pages of Rural's directory lacked the originality required for copyright protection.
Reasoning: The Court emphasized that copyright requires originality, defined as independent creation combined with some creativity.
Rejection of the 'Sweat of the Brow' Doctrinesubscribe to see similar legal issues
Application: The Supreme Court rejected the notion that mere effort in compiling facts grants copyright protection, emphasizing the necessity of originality.
Reasoning: The 'sweat of the brow' doctrine in copyright law has significant flaws, notably extending copyright protection to facts themselves rather than just the compiler's original contributions, such as selection and arrangement.