Despite the fact that a sequence produces spiritual, psychological, or physical benefits makes it “no less an idea, system, or process and no more amendable to copyright protection.” Further, the Court reasoned that “copyright protection for the sequence would prevent the public from engaging with Choudhury’s idea and building upon it.” The Court also noted that any such protection would have to find its grounding in patent law.Īdditionally, Choudhury argued that the sequence was entitled to copyright protection as a compilation and as a choreographic work. The Court reasoned that the yoga sequence falls into the idea exclusion because Choudhury himself described the sequence as “system or method designed to systematically work every part of the body.” He argued that the sequence is a healing art, which the Court rejected. The reason for the idea/expression dichotomy is to balance the need to protect the original expression while still encouraging others to build upon and improve an idea.
Bikram yoga sequence audio how to#
Thus, copyright protection extends to the book describing how to practice the sequence of yoga postures, but not to the sequence itself. § 102(b) expressly excludes protection for “any idea, procedure, process, system, method of operation, concept, principle, or discovery, regardless of the form in which it is described, explained, illustrated, or embodied in such work.” Section 102(b) represents the idea/expression dichotomy which says that the expression of an idea is eligible for copyright protection, but the idea itself is not. The Court first determined the yoga sequence was an unprotectible idea because 17 U.S.C. The district court granted Evolution’s motion for summary judgment holding that the “sequence is a collection of facts and ideas that is not entitled to copyright protection.” Evolution moved for partial summary judgment for Choudhury’s copyright infringement claim for the yoga sequence. In 2009 they founded Evolution Yoga, which offers multiple types of yoga including a style of hot yoga similar to Bikram yoga.Ĭhoudhury filed a complaint alleging that Evolution infringed the copyrighted works of Choudhury through the incorporation of the Bikram yoga sequence into Evolution Yoga classes. In 20 Mark Drost and Zefea Samson completed the three-month Bikram Yoga Teacher Training course. The very essence of the Bikram yoga sequence is the specific order the poses are performed, so that all muscles, tendons, and ligaments are warmed and stretched in a way they should be. Evolution Yoga, the Ninth Circuit held the Bikram Yoga sequence developed by Bikram Choudhury is not entitled to copyright protection because copyright protection is limited to the expression of ideas and does not extend to ideas themselves.īikram Choudhury developed a sequence of twenty-six yoga poses and two breathing exercises meant to be completed over the course of ninety minutes in a room heated to 105 degrees Fahrenheit, which were described in his copyrighted book published in 1979.
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