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CCC Information Services v. Maclean Hunter Market Reports, Inc., 44 F.3d 61 (1994)

SUBJECT:

Copyrightable material - valuations in a car buyers handbook

FACTS:

The Red Book was a book that provides potential used car buyers with valuations of the cars. A computer company, offering basically the same service, took the information in the Red Book and distributed it to the users of the computer program. Provider of computer database containing valuation information for used vehicles sought declaration against publisher of valuation information that database provider incurred no liability to publisher under copyright laws for its use of publisher's information. Publisher counterclaimed, alleging copyright infringement.

Procedure:

The United States District Court for the District of Connecticut, Alan H. Nevas, J., entered summary judgment for database provider, and publisher appealed.

ISSUE:

1) Whether the Red Book manifest originality so as to be protected by the copyright laws. (under 102a)

2) Is the material being copied?

RULE:

The selection and arrangement of data in the Red Book displayed amply sufficient originality to pass the low threshold requirement to earn copyright protection.

HOLDING:

The Court of Appeals, Leval, Circuit Judge, held that: (1) publisher's valuation information was sufficiently original to merit copyright protection; (2) copyright protection for compilation was not precluded by merger doctrine which stated that expression of idea which was inseparable from idea itself is not protectible; and (3) compilation was not in public domain on grounds that state statutes referenced its valuation. Reversed and remanded with instructions.

RATIONALE:

Compilation is a work formed by the collection and assembling of preexisting materials of data that are selected, coordinated, or arranged in such a way that the resulting work as a whole constitutes an original work of authorship.

POLICY/NOTES:

The ideas don't necessarily have to be novel; just the arrangement has to be.