Copyright Law Updates | New Judicial Opinions

May 24, 2007

Bryant v. Gordon

05 C 3066, 2007 WL 1063265, N.D. Ill., 4/6/2007

Bryant v. Gordon

Holding:

Even where subject matter of a photograph may not be copyrightable, individual expression of that idea, based on choice of angle, perspective, lighting and expression of subjects, can be protected.

Detailed Summary:

Plaintiff photographer alleged infringement of his copyright of a photo depicting two snipers dressed in Ghillie suits (customized camouflage suits), lying prone and sighting a target. Competitor argued that the photo was not protected because it merely portrayed a standard stance under military procedure and the idea of the photo was not copyrightable. Plaintiff asserted, and the court agreed, that his copyright covered the expression of that idea because it contained original elements such as choice of angle, perspective, lighting and expression of the subjects. The court then denied summary judgment on the infringement claim because (1) plaintiff had raised a reasonable inference of copying by showing defendants had access to his work and (2) using the “ordinary observer” test, a reasonable jury could find substantial similarity between the photos.

Also See:

FCC Adopts New Rules Permitting TV Channel Sharing by Broadcasters; Enacts First Step Towards Freeing UP Spectrum under Incentive Auction

FCC Modernizes Broadcast Television Public Inspection Files to Give the Public Online Access to Information Previously Available Only at TV Stations

Copyright Office Conducts Proceedings on Exemption to Prohibition on Circumvention of Copyright Protection Systems

Legislation to Deregulate Television Market Introduced in House and Senate

Copyright Office Proposes New Fee Schedule

Companies Mentioned

Copyright Law

The following companies are mentioned in Copyright Law Updates:

MGA Entertainment (HK) Ltd.

Mattel, Inc.

American Society of Composers, Authors, and Publishers

MGA Entertainment Inc.

UMG Recordings, Inc.

Bad Boy Entertainment, Inc. d.b.a. Bad Boy Records

Affordable Video Systems, Ltd.

Yahoo! Inc.

Dream Games of Arizona, Inc.

Television Music License Committee

Frank Diana City Entertainment

SESAC, Inc.

PC Onsite

RealNetworks, Inc.

AOL LLC f.k.a. America Online, Inc.

Northern Lights Products, Inc. d.b.a. GlowProducts.com

Litecubes, LLC

Poof Apparel Corp.

Derek Andrew, Inc.

Metro-Goldwyn-Mayer Pictures, Inc.

Geoffrey Productions, Inc.

Universal City Studios LLLP

Twentieth Century Fox Film Corp.

Turner Network Television LP, LLLP

Simon & Schuster, Inc.

Turner Network Sales, Inc.

Turner Classic Movies, LP, LLLP

Turner Broadcasting System, Inc.

The Cartoon Network LP, LLP

Paramount Pictures Corp.

NBC Studios, Inc.

Disney Enterprises, Inc.

Veoh Networks, Inc.

CSC Holdings, Inc.

CBS Broadcasting Inc.

Cablevision Systems Corp.

Cable News Network LP, LLLP

American Broadcasting Companies, Inc.

Westbound Records, Inc.

Kamind Associates, Inc. a.k.a. KAM Industries

Janice Combs Publishing, Inc. d.b.a. Justin Combs Publishing

All Headline News Corp.

Bad Boy Records LLC

American Software Development Company, Inc.

National Writers Union

IO Group, Inc.

Shelter Venture Fund LP

MLE Music

The Authors Guild, Inc.

Warner Bros. Entertainment Inc.

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