Dist. Ct. did not err in granting defendant’s motion for summary judgment in plaintiff’s copyright infringement action, where plaintiff asserted that defendant had used certain documents in bond offerings without plaintiff’s permission, where plaintiff had copyrighted said documents. Plaintiff was not entitled to copyright protection with respect to said documents, because plaintiff’s documents lacked sufficient originality for valid copyrights. Record showed that plaintiff’s documents were very similar to documents that had previously been prepared by Idaho Housing and Finance Association, and remaining non-trivial language that had been added by plaintiff in documents, which included short phrases and functional language, could not be copyrighted. As such, plaintiff could not pursue instant copyright infringement action against defendant or anyone else.
Federal 7th Circuit Court
Civil Court
Copyright