United States: The Threshold Of Copyright Protection After American Airlines

Originally published by Intellectual Property Law360, Transportation Law360.

In a century-old decision, Justice Oliver Wendell Holmes cautioned: "It would be a dangerous undertaking for persons trained only to the law to constitute themselves the final judges of the worth of pictorial illustrations, outside of the narrowest and most obvious limits."1 Even under present-day standards, the standard for copyright protection remains very low. To be copyrightable, a work need only be "original," that is, independently made and creative.2 "Minimal," "very slight," "modest" and "humble" — these are measures of creativity that courts and commentators have deemed sufficient to constitute copyright protection.3 But how much is not enough?

The U.S. Copyright Office's recent refusal to register the new American Airlines — a red, white and blue design suggestive of a bird in flight4 — has sparked discussion about the level of creativity a work must embody to warrant copyright protection. In our view, the courts have adopted more liberal standards for evaluating creativity than has the Copyright Office, reflecting a tension between the agency's determinations and the courts' more reasonable interpretations of "creativity."

We examine the "creativity question" in light of the American decision, as informed by relevant case law and the Copyright Office's more stringent rulings. We then suggest measures more liberal than those used by the Copyright Office for assessing copyright protection.

The American Airlines Ruling

The Refusal to Register

Since 2016, through its initial copyright application and a series of rejections and responses, American has waged battle to register a copyright in its mult-colored logo, suggestive of a bird in flight:

In its final refusal to register this logo, the Copyright Office rejected American's contention that the work was transformed beyond basic shapes by its arrangement or abstraction of those shapes. Rather, the Copyright Office characterized the logo as a "dual-colored, curved trapezoid with a bisecting, shaded and curved triangle" (i.e., the "beak" shape), exhibiting "insignificant variations in shape or coloring."5 The office concluded that this logo "falls below the threshold for creativity", characterizing it as "comprised of basic geometric shapes."6

Whether or not American will seek judicial review remains to be seen.7 Yet, as discussed below, we believe any such action would be well-grounded.

Why the Refusal Matters

Copyright subsists from the moments that a work is "fixed in a tangible medium of expression"8; registration with the Copyright Office is not necessary to obtain a copyright. Registration, however, has distinct advantages. In general, registration is necessary for a copyright owner to file an infringement suit.9 Registration also constitutes prima facie evidence of copyright validity, a useful tool in an infringement suit.10 Most significantly, with limited exceptions, statutory damages are only available when the copyright holder has registered its work, either before the infringement occurred or within three months of publication of the work.11

"Creativity" in Practice: Before the Courts and the Copyright Office

Before the Courts

Notably, legislative history leading up to the present-day Copyright Act of 197612 indicated a concern with requiring that works be "creative" to merit copyright protection. Some regarded the notion of "creativity" as problematic because it would require courts to make subjective judgments. The Authors League of America aptly summarized this fear, writing that "creativity" would "introduce an element that defies definition and could only promote litigation."13 Noted copyright lawyer and authors' rights advocate Irwin Karp shared a similar concern, remarking: "[adding] a condition that a work must be 'creative' ... involves considerable difficulties and risks ... . If courts were required to provide a definition for [creativity], a wide range of criteria could develop."14 In part because of these concerns, the Copyright Act of 1976 did not codify a "creativity" requirement, aiming instead to "[maintain] the standards of originality and creativity developed by the courts under the existing law." 15

The U.S. Supreme Court subsequently considered the threshold for copyright protection in its seminal Feist decision. While finding that alphabetized white pages of a telephone directory were not copyrightable, the court emphasized that the amount of creativity necessary for copyright protection is "extremely low"; even independent elements that are unprotectable may be protected by copyright when selected or arranged in an original way16. According to the court, only those works that are "garden-variety," "typical," "obvious," reflect "an age-old practice" and are "commonplace" are not copyrightable.17

American Airlines' "bird" is not the first matter involving the eligibility of shapes for copyright protection. Both pre-Feist and post-Feist decisions have considered whether works consisting of geometric shapes warrant copyright protection. For example, cases decided in the 1970s (prior to passage of the 1976 Copyright Act) found a filigree pattern formed of intercepting straight lines and arc lines sufficiently creative to merit protection,18 as well as fabric pattern of strip of crescents, ribbons between that strip and then rows of semicircles.19

The D.C. Circuit cases involving Atari's video game "Breakout," decided before and after Feist, illustrate the different ways that the courts and the Copyright Office have interpreted the "creativity" threshold. At issue in Atari was a video game encompassing a wall of multicolored rectangles resembling bricks, a rectangular paddle, and square balls that the players hit against the wall with the paddle to smash the bricks. The Copyright Office initially refused registration of the game, finding that neither the common geometric shapes not their coloring were copyrightable, and the district court affirmed. The D.C. Circuit vacated and remanded, mandating that the Copyright Office reconsider copyrightability of the game consistent with the D.C. Circuit's view that "simple shapes, when selected or combined in a distinctive manner indicating some ingenuity, have been accorded copyright protection."20 After yet a second refusal to register, the case was "replayed" in the D.C. Circuit, with the court again indicating that the Copyright Office got it wrong. The D.C. Circuit explained "[a]bstract representation" is "neither an 'obvious' nor an 'inevitable' choice. Nor is the coordination of a square 'ball' and a rectangular shrinking paddle a 'time-honored' or 'conventional' combination."21

Other post-Feist cases echo the principle that a combination of geometric shapes, even if unprotectable individually, may merit copyright protection as a whole. For example, a federal court held that the famous Lombardi Trophy, awarded to the Super Bowl winner, is subject to copyright protection.22 Rejecting the argument that the trophy, consisting of a replica football sitting atop a three-sided base with tapered side, was not subject to copyright protection, the court observed: "at some level of abstraction, all objects are combinations of geometric shapes; that does not mean they cannot be protected by copyright. ... it is the trophy's combination of the base, with the football on top, at a certain angle, that is protectable."23 Likewise, in Glasscraft Door I LP v. Seybro Door & Weathership Co. Inc.24, the court found the plaintiff's decorative door panels, containing simple geometric shapes such as arches, ovals and stars, were eligible for copyright protection. Again, although the individual shapes were not copyrightable, "a work comprising uncopyrightable elements may, through original organization and presentation, be protected by copyright law."25

Cases Before the Copyright Office

The Copyright Office's more stringent view on what constitutes copyrightable subject matter tracks the agency's "Compendium," which is intended as a technical manual for the office and a guidebook for the courts and general public.26 According to Section 906.1 of this manual, "[t]he Copyright Act does not protect common geometric shapes, either in two-dimensional or three-dimensional form. ... the U.S. Copyright Office will not register a work that merely consists of common geometric shapes unless the author's use of those shapes results in a work that, as a whole, is sufficiently creative." This section, however, is not very illuminating. It provides, as examples of unregistrable material, a "standard pentagon" and "smooth marble sphere," as well as white dots evenly spaced on a purple background — none of which, we submit, bears any resemblance to American's logo or rises to its level of creativity.

Consistent with the "Compendium," the Copyright Office has adopted a more restricted view than have the courts of what constitutes copyrightable subject matter.27 The office has frequently refused to register combinations of geometric shapes. While a few such decisions appear well-grounded, many stray from Feist's mandate that the level of creativity sufficient to sustain copyright protection should be "very slight" and "minimal."28

During the past several years, the Copyright Office Review Board has considered over 100 requests for reconsideration of refusals that were based, at least in part, on a finding of insufficient creativity. The board affirmed nearly all of these refusals. A few were well-founded. For example, the board upheld the denial to register a repeating group of Greek keys, finding the below design to be a "simple, minor variation on common shapes or symbols consisting of a few simple geometric designs arranged in an obvious manner."29

Similarly, the board's refusal of Adidas' three-bars logo on the basis that the logo consisted of nothing more than a "basic combination" of "public domain shapes" seems appropriate.30

Many other decisions, however, are not so well-grounded; indeed, they show that the board has required far more than "minimal" creativity to register geometric shapes. It refused, for example, registration of a work that it deemed to be no more than a "C" and a "T" nested together to resemble "several common symbols and designs":31

That the board found this selection and arrangement of shapes and letters to lack even a minimal amount of creativity highlights the overly strict approach it has adopted to recognizing creativity in groups of geometric shapes.

Likewise, in affirming the refusal to register the BlackBerry Messenger icon, the board revealed its stringent view of what an arrangement of geometric shapes must look like to be sufficiently creative:32

Oddly, the board found this selection and combination of elements to be nothing more than "a few familiar symbols or designs."33

The board's exacting demands for creativity are well-summarized in its refusal of the "UAC Triangle Design." Here, the board's reasoning is especially telling: It found the combination of geometric shapes to lack creativity where they were "not arranged in a way that creates a new, unfamiliar shape."34 This view, we submit, far exceeds Feist's low threshold.

What Should the Measure of Creativity Be?

Given Feist's emphasis on the low threshold of creativity, any collection of geometric shapes exhibiting the following characteristics should be eligible for copyright protection:

  • A deliberate choice of elements, which, as the case law has observed, shows creativity, even according to the Copyright Office's own "Compendium." See President and Fellows of Harvard College v. Elmore (observing that, in discussing whether combinations of geographic shapes merit copyright protection, the manual "emphasizes creative choices").35
  • The modification of traditional shapes, which demonstrates creative thought and effort, even in fashioning individual elements of a work; and
  • Something more than mere stock shapes or repeating patterns of stock shapes.

Protection for "suggestive" trademarks may also provide a useful analogy. As articulated in Abercrombie & Fitch Co. v. Hunting World,36 trademark law accords marks varying degrees of protection along a "spectrum of distinctiveness," with the more distinctive marks awarded the most trademark protection. "Suggestive" marks immediately merit protection. As the Abercrombie court explained "[a] term is suggestive if it requires imagination, thought and perception to reach a conclusion as to the nature of goods."37 Likewise, a work that suggests a representational image, and requires some leap of the imagination on the viewer's part to divine that image, should arguably warrant copyright protection. This is not to say that a work must be suggestive and abstract to be copyrightable. To be contrary, many representational works, such as those Grandma Moses, the famous 20th century folk artist, are undeniably subject to copyright protection. We simply advocate for a new factor in assessing copyrightability, i.e., that a design "suggestive" of a representational image is sufficient (although not necessary) for a work to merit copyright protection.

Measured against these standards, American's logo is plainly a copyrighted work. To be sure, this bird-in-flight is not a modern day masterpiece. But it is, at the very least, a combination of geometric shapes sufficient to warrant copyright protection consistent with decisions such as Feist, the Atari cases, Titlecraft and the measures of copyrightability we espouse here. Indeed, American's logo reflects a deliberate choice to combine different geometric shapes into an integral whole. Even in the Copyright Office's own words, the shapes are not stock or repetitive geometric figures, but instead are creatively modified (i.e., a "curved trapezoid" and a "bisecting, shaded and curved triangle"). And, they suggest the image of a bird-in-flight, requiring the viewer to make an interpretive leap of the imagination.

Conclusion

The reader should recognize the images below as paintings by the famed artists Mark Rothko and Pablo Picasso. No one would reasonably contend that these renowned artists created works that were not copyrighted. Yet, like American's logo, they are "comprised of basic geometric shapes." If these works are creative, American's bird-in-flight should take wing, joining the ranks of copyrighted works.

Mark Rothko
Pablo Picasso's Cubist Period

Footnotes

1. Bleistein v. Donaldson Lithographing Co., 188 U.S. 239 (1903).

2. Feist Publ'ns, Inc. v. Rural Telephone Serv. Co., Inc., 499 U.S. 340, 363-364, (1991); 17 U.S.C. § 102(a).

3. Atari Games Corp. v. Oman, 888 F.2d 878, 883 (D.C. Cir. 1989) (hereinafter "Atari I"); Nimmer on Copyright (2017), §2.08.

4. Letter from U.S. Copyright Office Review Board to Andrew J. Avsec (Jan. 8, 2018).

5. Id. at 4.

6. Id. at 4, 5.

7. Such review is available under the Administrative Procedure Act, 5 U.S.C. § 706.

8. 17 U.S.C. § 102.

9. An applicant who is refused registration may also sue for infringement, but must serve notice upon the Register of Copyrights, which may intervene in the suit and defend denial of registration. See 17 U.S.C. § 411(a).

10. 17 U.S.C. § 410(c) (registration within five years of publication is prima facie evidence that the copyright is valid).

11. See 17 U.S.C. §§ 411, 412(2).

12. 17 U.S.C. § 101 et seq.; See generally George S. Grossman, Omnibus Copyright Revision Legislative History (William S. Hein & Co., Inc. 2001).

13. Letter from The Author's League of America, Inc., to The Committee on the Judiciary (Feb. 23, 1962), reprinted in George S. Grossman, 3 Omnibus Copyright Revision Legislative History: U.S. Copyright Office Report Discussion Draft 1961-1964 (Parts 1-4) 260 (William S. Hein & Co., Inc. 2001).

14. Letter from Irwin Karp, to the Committee on the Judiciary (May 29, 1961), reprinted in George S. Grossman, 3 Omnibus Copyright Revision Legislative History: U.S. Copyright Office Report Discussion Draft 1961-1964 (Parts 1-4) 313 (William S. Hein & Co., Inc. 2001).

15. Copyright Law Revision: Hearings before the Subcomm. on Courts, Civil Liberties, and the Admin. of Justice of the H. Judiciary Comm. on H.R. 2223, 94th Cong., 1st Sess. 2052 (1975).

16. Feist, 499 U.S. at 345, 348.

17. Id. at 362-63.

18. Tenn. Fabricating Co. v. Moultrie Mfg. Co., 421 F.2d 279 (5th Cir. 1970).

19. Soptra Fabric Corp. v. Stafford Knitting Mills, Inc., 490 F.2d 1092 (2d Cir. 1974).

20. Atari I at 883. The court stated "We are thus uncertain whether or how the Register's decision on BREAKOUT harmonizes with prior Copyright Office actions and court rulings on the creativity threshold."

21. Atari Games Corp. v. Oman, 979 F.2d 242, 247 (D.C. Cir. 1992) (hereinafter "Atari II").

22. Titlecraft, Inc. v. Nat'l Football League et al, No. 10-758 (RHK/JJK), 2010 WL 5209293 (D. Minn. Dec. 20, 2010).

23. Id. at *4 (citing Feist, 499 U.S. at 362).

24. No. H-08-2667, 2009 WL 3460372 (S.D. Tex. Oct. 22, 2009)

25. Id. at *3

26. https://www.copyright.gov/comp3/announcement.html

27. Commentators have previously remarked upon this the Copyright Office's narrow interpretation of copyrightability. See Katherine L. McDaniel, James Juo, "A Quantum of Originality in Copyright", 8 Chi.-Kent J. Intell. Prop. 169 (2009) (noting "some reluctance by the Copyright Office to register works that could be characterized as simple combinations of standard design elements" and critiquing the Copyright Office for placing undue emphasis on "whether the elements of a work can be categorized as being 'simple,' rather than on whether the combination of those elements is the expected or mechanical result of a commonplace practice.").

28. Feist, 499 U.S. at 345.

29. Letter from Copyright Office Review Board Member to Shanna K. Sanders, Heslin Rothenberg Farley & Mesiti P.C. (Jan. 31, 2018), https://www.copyright.gov/rulings-filings/review-board/docs/wonkey_key.pdf.

30. Letter from Copyright Office Review Board Member to Angela Notaro, Law Office of Notaro, Michalos & Zaccaria P.C. (Apr. 20, 2016), https://www.copyright.gov/rulings-filings/review-board/docs/adidas-3-bars.pdf.

31. Letter from Copyright Office Review Board Member to Johnathan Hyman, Knobbe, Martens, Olson & Bear LLP (Oct. 23, 2017), https://www.copyright.gov/rulings-filings/review-board/docs/blade-piercing-skin.pdf.

32. Letter from Copyright Office Review Board Member to Justin E. Pierce, Venable LLP (Aug. 15, 2016), https://www.copyright.gov/rulings-filings/review-board/docs/blade-piercing-skin.pdf.

33. Id.

34. Letter from Copyright Office Review Board Member, to D. Wade Cloud, Jr. (Jan. 31, 2018), https://www.copyright.gov/rulings-filings/review-board/docs/uac-triangle-design.pdf.

35. No. CIV-15-00472-RB-KK, 2016 WL 749274, at *8 (D.N.M. May 19, 2016).

36. 537 F.2d 4, 9-11 (2d Cir. 1976).

37. Id. at 11.

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