Design Basics, LLC v. Signature Construction, Inc.

Federal 7th Circuit Court
Civil Court
Copyright
Citation
Case Number: 
No. 19-2716
Decision Date: 
April 23, 2021
Federal District: 
C.D. Ill.
Holding: 
Affirmed

Dist. Ct. did not err in granting defendant's motion for summary judgment in plaintiff's action, alleging that defendant infringed on plaintiff's copyright, by copying plaintiff's designs for homes. Plaintiff's copyright in design of instant suburban, single-family home, with many standard elements and limited possibilities for creativity was "thin," such that, under Lexington Homes, 858 F.3d 1093, plaintiff was required to show that defendant's design was virtually identical to its own design. Plaintiff, though, failed to make requisite showing, where record demonstrated that defendant's designs had greater square footage than plaintiff's designs, as well as had different room dimensions, different ceiling heights and different garage configurations. Ct. further noted that defendant's design plans were dissimilar enough to preclude liability under ordinary substantial-similarity analysis.