Mason v. Montgomery Data, Inc.
, 967 F.2d 135 (1992) p 176SUBJECT:
Copyrightable material - maps
FACTS:
Plaintiff created set of maps. Defendant copied the maps.
Procedure:
District court initially held that Mason could not recover statutory damages or attorney's fees.
ISSUE:
Whether the maps were copyrightable.
RULE:
The plaintiff's maps possess sufficient creativity in both the selection, coordination, and arrangement of the facts that they depict.
HOLDING:
The maps are copyrightable.
RATIONALE:
The district court's judgment was reversed and the case remanded. The merger doctrine was inappropriately applied here. The maps are original. Originality does not require novelty, ingenuity, or aesthetic merit.
POLICY/NOTES:
The Copyright Act categorizes maps not as factual compilations, but as "pictoral, graphic, and sculptural works."
Originality means only that the work was independently created by the author (as opposed to copied from other works).