Bikram's Yoga College v. Evolution Yoga

Summarized by:

  • Court: 9th Circuit Court of Appeals Archives
  • Area(s) of Law: Copyright
  • Date Filed: 10-08-2015
  • Case #: 13-55763
  • Judge(s)/Court Below: Circuit Judge Wardlaw for the Court; Circuit Judges Noonan and Murguia
  • Full Text Opinion

Copyright law protects only an expression of an idea, the words and pictures that describe the idea, but does not protect the idea itself.

Bikram Choudhury, a famous yoga specialist, developed a “Sequence” that consisted of twenty-six individual yoga poses and two breathing exercises. He used this Sequence, and began teaching “Bikram Yoga” by practicing the sequence in ninety minute intervals in a room heated to 105 degrees Fahrenheit. Choudhury published a book describing the twenty-six poses of the Sequence with photos, drawings, and descriptions of how to perform the poses. Choudhury registered both the book and the “compilation of exercises” referenced in the book with the U.S. Copyright Office. Choudhury also created a Bikram Yoga Teacher Training Course in 1994, where Mark Drost and Zefea Samson enrolled and successfully completed the course. In 2009, Drost and Samson founded Evolution Yoga, offering “hot yoga” which was extremely similar to Bikram Yoga. In 2011, Choudhury filed suit, alleging that Evolution Yoga had infringed on his copyright for Bikram Yoga. The district court ruled that the exercises were a series of facts and ideas, and were not entitled to copyright protection. On appeal, the Ninth Circuit reviewed whether the idea behind Bikram Yoga was copyrighted. 17 U.S.C. §102(b) excludes copyright protection for ideas, processes, systems, methods of operation, concepts, or discovery regardless of how it was portrayed. Section 102(b) classifies the idea/expression dichotomy where every idea, theory, or fact of the copyrighted work becomes public at the moment of publication. Looking at Baker, the distinction between ideas and expression is that the copyright for a work that describes how the process is performed does not extend to the process itself. Therefore, the panel held that the copyright for the 1979 book did not extend to the Sequence itself, because the subject matter was an idea, process, or system that improved people’s health, rather than an expression of that idea. AFFIRMED.

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