Copyright Litigation: Victory for Music Educator and Music Boosters in the 9th Circuit Court of Appeals

The Burbank High School show choir, which was the basis for the television series Glee, has been involved in a long running copyright litigation battle waged by Tresona Multimedia, LLC (“Tresona”). A significant decision was published earlier today by the Ninth Circuit Court of Appeals, which is embedded below. This is a fact intensive post, so please read closely.

Summary: Tresona is a music licensing company. Burbank (Ca.) High School has several show choirs. In 2017, Tresona filed a copyright infringement lawsuit against Brett Carroll, the Burbank HS choir director, the Burbank HS Vocal Music Association Boosters Club, several Booster Club parents. Why the plaintiff chose to name the individuals, particularly the Booster Club parents, is a mystery.

All of the facts that follow are integral to the result that the Court reached: The performers are Burbank High School students. Because the costs of the ensemble are not covered by the School District’s budget, the Boosters Club (a 501(c)(3) tax exempt organization) holds several fundraising concerts. One of these is an annual show choir competition. The Boosters sell tickets and advertisements in the programs for these events.

During one particular such fundraiser, one of the Burbank HS choirs performed a two minute excerpt of “Magic”, by Olivia Newtown-John. Burbank’s performance of “Magic” was contained in a medley of other songs. Similarly, Burbank HS performed a sixteen second excerpt of “(I’ve Had) the Time of My Life” by Bill Medley and Jennifer Warner, which runs four minutes and twenty two seconds in total.

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Copyright Law Update: All About Fair Use

(The following is an excerpt from my book risk, create, change: a survival guide for startups & creators, now available here at Amazon.com.)

    One of the key doctrines of copyright law is the concept of fair use.  Fair Use is, simply stated, a defense to a copyright infringement claim.  This doctrine allows for, in certain, limited circumstances, the unlicensed use of copyrighted works. 

    The Copyright Act provides provides the statutory framework for determining whether something is a fair use and identifies certain types of uses—such as criticism, comment, news reporting, teaching, scholarship, and research—as examples of activities that may qualify as fair use. 

    Generally speaking, only a federal court after a copyright infringement case has been filed can really determine if one’s actions in using a copyrighted work constitutes Fair Use and is thus permissible.  From a startup or entrepreneur’s standpoint, if you are in the educational space or publishing space involving artistic criticism, Fair Use becomes a significant debate at the office.  For the purposes of this paragraph, “publishing” could include not only the written word but also video blogging and related content production. 

    There are four factors that courts will consider in determining if the unlicensed use of a copyrighted work constitutes Fair Use:

  1. the purpose and character of the use, including whether such use is of a commercial nature or is for nonprofit educational purposes;
  2. the nature of the copyrighted work;
  3. the amount and substantiality of the portion used in relation to the copyrighted work as a whole; and
  4. the effect of the use upon the potential market for or value of the copyrighted work.

    Since Fair Use is such a generally applicable topic, it bears some additional explanation.  The first factor in the fair use analysis focuses on what the purpose and character of the use is, including whether the use is of a commercial nature or is for nonprofit educational purposes.  A key part of the analysis here is how the party claiming Fair Use is using the copyrighted work.  Courts are much more likely to find that nonprofit organizations using copyrighted material for educational and noncommercial uses qualify as Fair Use.   One should not automatically assume, however, that all nonprofit education and noncommercial uses are automatically fair and all commercial uses are not fair.  This first factor is only part of the four part analysis, and it is the court’s analysis of all of the factors as a whole that will determine the outcome.

    “Transformative” uses are more likely than not to be considered fair.   Transformative uses are those that add something new, furthering the purpose of the original work or imbuing the original work with a different character.

    The second factor focuses on the nature of the copyrighted work.  This can be a slippery concept.  The analysis here is the degree to which the copyrighted work that was used relates to the overarching purpose of copyright law in encouraging creative expression.  In other words, when someone uses a copyrighted work that is a novel, movie or song - all forms of creative expression - that person is less likely to be entitled to argue the Fair Use doctrine.  If the copyrighted work was a news story or a technical article, the it is more likely that Fair Use could be found in that circumstance.

    The third factor focuses on the amount and substantiality of the portion used in relation to the copyrighted work as a whole.  In short, how much of the copyrighted work was used?  Here courts would look at both the quantity and quality of the copyrighted material that was used.  Not surprisingly, the larger the portion of the copyrighted work used, the less likely it will be that Fair Use will be found.  Also, the converse is also true.  The smaller amount of the copyrighted work used, the more likely that a court would determine Fair Use was applicable in the situation.  In some contexts, using even a small amount of a copyrighted work was determined not to be fair because the selection was an essential part—or the “heart”—of the work.

    The fourth and final part of the Fair Use analysis focuses on the effect of the use upon the potential market for or value of the copyrighted work.  Does the use harm the copyright holder’s asset?  The court would have to examine the existing or future market for the copyright owner’s original work. Does the use  harm the copyright owner by displacing sales of the original owner’s work that would have happened but for the infringing user’s activities? This is probably the last place on earth where you would want the monetary value of your property to be determined, especially if your work is avant garde or there is no clearly established market (yet) for your product.  

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Lucasfilm Alleges Copyright Infringement by Lightsaber Academy

When you are the owner of one of the most valuable film franchises in history, you have to take steps to protect your intellectual property ("IP").  Lucasfilm certainly can't be faulted for that.  

Lucasfilm has filed suit in federal court in California to enforce its rights against a school calling itself the Lightsaber Academy, which advertises that it teaches the "Art of Lightsaber Combat", and various instructor certifications for a fee.   Thus, the Lightsaber Academy people look like they are engaging in a commercial activity while utilizing the words "Jedi" and "Lightsaber". 

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Copyright Infringement or Mere Inspiration?

Remember when attorneys for Robin Thicke and Pharrell filed a lawsuit which was basically a preemptive strike against the Estate of Marvin Gaye on the issue of whether the song “Blurred Lines” infringed on  Mr. Gaye’s “Got to Give it Up“?  Well, it didn’t have the effect that the plaintiffs envisioned – the defendant, the Estate of Mr. Gaye, ended up with a $5.3 Million judgment on a counterclaim for copyright infringement against the plaintiffs.

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