Feist Publications, Inc. v Rural Telephone Service Company
The 1991 U.S. Supreme Court case "Feist Publications, Inc. v. Rural Telephone Service Co." is a significant decision in copyright law. This case reached the Supreme Court due to its implications on the concept of originality in copyright law, which is a fundamental criterion for copyright protection.
- Elevation to the Supreme Court: The case was elevated to the Supreme Court primarily because it presented a significant legal question about the degree of originality required for copyright protection. The dispute centered around Feist Publications' use of information from Rural Telephone Service's telephone directory to compile a regional phone directory. The key issue was whether the compilation of a phone directory, essentially a factual listing, qualified for copyright protection, particularly considering that it lacked substantial creative input. This issue was of great importance because it touched upon the balance between encouraging creativity (through copyright protection) and allowing the free use of facts and information, a principle integral to freedom of expression and the advancement of knowledge. The case was seen as a chance for the Supreme Court to clarify the standards of originality required for copyright protection, a matter with wide-ranging implications in the information age.
- Outcome of the Court's Decision: The Supreme Court's decision, delivered in 1991, was a landmark ruling that set a new standard for copyright originality. The Court held that a mere compilation of factual information, like a phone directory, did not possess the requisite level of creativity to qualify for copyright protection. The decision emphasized that copyright protects only the expression of ideas and not the ideas themselves, or the facts. In this specific case, the Court concluded that Rural Telephone Service's white pages directory was not original in the sense that it constituted a mere alphabetical listing of telephone subscribers, without any creative input in the selection or arrangement of the data. This ruling significantly narrowed the scope of copyright protection, especially for compilations of factual data, and underscored the distinction between facts (which are not copyrightable) and the creative expression of ideas or information (which are copyrightable).
In essence, the "Feist Publications, Inc. v. Rural Telephone Service Co." case established a key precedent in copyright law, clarifying that a certain degree of creativity is essential for a work to be eligible for copyright protection, thereby setting a threshold that differentiates between mere data compilation and creative expression.
In 1991 the U.S. Supreme Court heard the case of Feist Publications, Inc. v. Rural Telephone Service Company.
In that case, Feist and Rural Telephone both published telephone directories that competed for advertisers. The Feist telephone directory covered 15 counties, one of which included the Rural Telephone service area. Rural refused to license its telephone directory information to Feist; therefore, Feist copied the Rural telephone directory information.
The court's decision
The court sided with Feist, and held that copyright protection afforded to databases (which was how Rural presented its directory information to the court)
was thin, extending only to the author's selection and arrangement of the data.
The court also held that listing the names and numbers of all subscribers in a telephone service area in alphabetical order does not satisfy the minimum "original work of authorship"requirement for copyright protection.
Consequences of the court's decision
As a consequence of the Feist decision, businesses that create and maintain databases currently have very limited protection under United States copyright laws. That protection now covers only the original selection, coordination, and arrangement of data, but not the data itself. Furthermore, the selection, coordination, and arrangement are protected only to the extent that they satisfy the creativity requirement of being an "original work of authorship."
Information Infrastructure Task Force (IITF)
In 1993, the Information Infrastructure Task Force (IITF) was formed. The IITF has established a working group on intellectual property rights to examine issues pertinent to intellectual property.
In July 1994, the group published the Green Paper, a preliminary report on intellectual property rights.
This group has recognized the need to review current copyright laws in light of the fact that copying and disseminating information are easy with electronic media.
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