Yoga Sequence not Protected by Copyright, says 9th Circuit

Depositphotos_43752505_s-2015 © iphemantOn October 8, 2015, the U.S. Court of Appeals for the Ninth Circuit ruled that a sequence of yoga poses and breathing exercises was not entitled to copyright protection under the U.S. Copyright Act. Bikram’s Yoga College of India v. Evolation Yoga, No. 13-55763 (9th Cir. Oct. 8, 2015).

PLAINTIFFS’ CLAIMS. The plaintiffs contended that the yoga sequences in question–26 poses and two breathing exercises developed by Bikram Choudhury and described in his book Bikram’s Beginning Yoga Class–were entitled to copyright protection as a choreographic work. Since the enactment of the 1976 Copyright Act, “pantomimes and choreographic works” have been eligible for copyright protection. However, the court determined that although the poses and exercises possessed aesthetic attributes, “at bottom, the Sequence is an idea, process, or system designed to improve health.” For this reason, the court concluded that the sequence was ineligible for copyright protection under 17 U.S.C. § 102(b).

© vision.siTHE IDEA/EXPRESSION DICHOTOMY. Section 102(b) of the Copyright Act expressly excludes protection for “any idea, procedure, process, system, method of operation, concept, principle, or discovery, regardless of the form in which it is described, explained, illustrated, or embodied in such work.” This statute codifies the well-known “idea/expression dichotomy”–the principle that copyright protects only the expression of an idea, but does not award exclusive rights as to the underlying idea itself. Other courts have invoked the idea/expression dichotomy to deny copyright protection to process-ideas such as meditation exercises, see Palmer v. Braun, 287 F. 3d 1325 (11th Cir. 2002), food recipes, see Publications International, Ltd. v. Meredith Corp., 88 F. 3d 473 (9th Cir. 1996), and a manual describing how to organize roller-skating races, see Seltzer v. Sunbrock, 22 F. Supp. 621 (S.D. Cal. 1938).

AN UNPROTECTABLE PROCESS, NOT A CHOREOGRAPHIC WORK. The claimants argued that the yoga sequence in question met the literal definition of a choreographic work as used by the U.S. Copyright Office. However, the court observed that the claimants themselves described the sequence as a “system” or “method” designed to “systematically work every part of the body, to give all internal organs, all the veins, all the ligaments, and all the muscles everything they need to maintain optimum health and maximum function.” In light of this and other statements by the claimants, the court concluded that they were “attempt[ing] to secure copyright protection for a healing art: a system designed to yield physical benefits and a sense of well-being. Simply put, this attempt is precluded by copyright’s idea/expression dichotomy, codified in Section 102(b).”

The court explained that even if the yoga sequence could be described in a manner that would meet the Copyright Office’s definition of a choreographic work, this would not alter the conclusion that the sequence constituted an unprotectable idea or process. The court wrote that,

The Sequence is not copyrightable as a choreographic work for the same reason that it is not copyrightable as a compilation: it is an idea, process,or system to which copyright protection may“[i]n no case” extend. 17 U.S.C.§102(b). We recognize that the Sequence may involve“static and kinetic successions of bodily movement in certain rhythmic and spatial relationships.” Compendium II,§ 450.01. So too would a method to churn butter or drill for oil. That is no accident: “successions of bodily movement”often serve basic functional purposes. Such movements do not become copyrightable as “choreographic works” when they are part and parcel of a process. Even if the Sequence could fit within some colloquial definitions of dance or choreography, it remains a process ineligible for copyright protection.

The idea/expression dichotomy … plays a similar role in defining the scope of protection for a choreographic work as it does for compilations…. In the context of choreographic works, that role is essential. Our day-to-day lives consist of many routinized physical movements, from brushing one’s teeth to pushing a lawnmower to shaking a Polaroid picture that could be … characterized as forms of dance. Without a proper understanding of the idea/expression dichotomy, one might obtain monopoly rights over these functional physical sequences by describing them in a tangible medium of expression and labeling them choreographic works. The idea/expression dichotomy thus ensures that expansive interpretations of the categories enumerated as proper subjects of copyright will, “[i]n no case,” extend copyright protection beyond its constitutional limits. 17 U.S.C. §102(b).

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Common Catalogue Listing not Proof of Plant Variety Rights Ownership


In July 2015, a court in the city of Milan, Italy held that the Italian subsidiary of BASF failed to establish its ownership of plant variety rights in a lawsuit that BASF brought against a local company. BASF Italia S.p.A. v. Società Agricola Magnani Caterina e Magnani Lorenza, No. 8745/15 (Ct. Milan, Bus. Chamber A, 16 July 2015).

BASF Italia sued Società Agricola Magnani, alleging that it infringed European patents relating to its Clearfield® rice planting system and plant variety rights held by BASF in the variety POLLUX CL, a rice variety said to be especially resistant to imidazolinone herbicides. BASF first obtained, through ex parte proceedings, an order to search Magnani’s fields and to inspect rice seedlings and seeds found there. Subsequently, it sought an injunction and damages against Magnani for alleged patent and plant variety rights infringement.


Responding to the patent infringement allegations, Magnani contended that it had been authorized by BASF to use the CLEARFIELD technology with respect to another rice variety known as SIRIUS. Regarding BASF’s allegations that Magnani had infringed BASF’s plant variety rights, Magnani observed that it had previously lawfully obtained a supply of seed of the POLLUX variety for experimental cultivation. It contended that any remaining POLLUX plants in its fields were being grown solely for propagating purposes, and thus its conduct was exempt from liability under Article 14 of Council Regulation (EC) No 2100/94 of 27 July 1994 on Community plant variety rights.

In a decision dated 16 July 2015, the court held that BASF had failed to establish its ownership of a plant variety rights registration for the POLLUX CL variety. According to the court, all that BASF had shown was that the variety was included in the “common Catalogue of varieties of agricultural plant species” established by Council Directive 2002/53/EC of 13 June 2002 on the common catalogue of varieties of agricultural plant species. That directive requires all EU Member States to publish one or more national catalogues of plant varieties accepted for certification and marketing in their territories. Among the criteria for recording a variety in such a common catalogue, the variety must be “distinct, stable, and sufficiently uniform.” The variety must also have a satisfactory value for cultivation and use.

The court acknowledged that the Directive 2002/53 criteria of distinctiveness, stability, and uniformity are similar to the prerequisites for registration of plant variety rights under Regulation 2100/94. However, the court emphasized that the inscription of a variety in the common catalogue–whose primary purpose is the protection of health–is not the equivalent of, or a substitute for, obtaining a registration for plant variety rights–whose object is to award intellectual property rights. In the present case, the court observed that the allegedly unauthorized reproduction by Magnani of the allegedly protected rice variety occurred prior to the appearance of the variety in the common catalogue. For these reasons, the court dismissed BASF’s allegations that Magnani infringed its plant variety rights.

With regard to BASF’s allegations that Magnani infringed its patents, the court determined that additional investigation was necessary before the court could address the allegations.

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Canadian Supreme Court: Claimants May Seek to Enforce Ecuadorian Judgment against Chevron in Ontario

Canada Supreme CourtOn 4 September 2015, Canada’s highest court dismissed arguments by US petrochemical company Chevron that Canadian courts cannot hear proceedings to enforce the US$ 9.51 billion judgment of an Ecuadorian court against it. Chevron Corp. v. Yaiguaje, 2015 SCC 42. The Ecuadorian judgment, which arises from alleged environmental contamination and destruction by Chevron’s predecessor Texaco in the Lago Agrio region of Ecuador, has been attacked by Chevron in other fora as a product of corruption and other unlawful practices instigated by the claimants’ attorneys. In the Canadian litigation, Chevron primarily argued that Canadian courts should not and could not hear proceedings to enforce the judgment because the Ecuadorian litigation had no relationship with Canada. In its 4 September judgment, however, the Canadian Supreme Court ruled that in such cases,

… the only prerequisite is that the foreign court had a real and substantial connection with the litigants or with the subject matter of the dispute, or that the traditional bases of jurisdiction were satisfied. There is no need to demonstrate a real and substantial connection between the dispute or the defendant and the enforcing forum.

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Criminal Convictions in Salmonella Case

food lawA U.S. federal jury convicted three former food company executives of several crimes relating to a 2008-09 outbreak of Salmonella infections resulting from the production and distribution of adulterated peanut butter. See Verdict Form, United States of America v. Parnell, No.  1:13-CR-12 (M.D. Ga. Sept. 19, 2014). The jury in Albany, Georgia found Stewart Parnell, one-time owner of the now-defunct Peanut Corporation of America (“PCA”), guilty of 67 criminal counts for offenses including mail and wire fraud, conspiracy, obstruction of justice, and the introduction of adulterated and misbranded food into interstate commerce with fraudulent intent. The jury also convicted Stewart’s brother, Michael Parnell, and Mary Wilkerson, a former quality control manager at one of PCA’s plants, of a smaller number of related crimes.

Although the defendants were not charged with having caused any deaths, hundreds of cases of sickness and nine deaths have been attributed to the Salmonella outbreak. See Unprecedented: Peanut Corp. executive convicted for deadly salmonella outbreak, (Sept. 19, 2014). Authorities identified a leaky roof and filthy conditions at a PCA manufacturing facility, as well as the presence of water in what should have been a dry process, as reasons for the contamination of PCA’s products with the deadly bacterium. According to prosecutors, the Parnell brothers employed fake laboratory tests to speed up the shipment of their products and distributed peanut butter and peanut paste despite their knowing that it was tainted with Salmonella.

Stewart Parnell could face more than 30 years in prison for the crimes of which he was convicted.


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3 Months in Spanish Prison for Plant Variety Rights Infringement

Jerez de la Frontera Flag, Spain.On July 10, 2014, a criminal court in southwestern Spain sentenced a grower of carnation flowers to three months in prison, plus a fine of € 360 EUR, for infringing plant variety rights in violation of Article 274.3 of the Spanish Penal Code. Sentencia No. 271/14 (Juzgado de lo Penal nº 1 de Jerez de la Frontera 10 Jul. 2014). The court, situated in Jerez de la Frontera, in the Province of Cádiz, Andalusia, ruled that the defendant had improperly acquired propagating material of the carnation varieties denominated WESTDIAMOND, HILOPTA, and HILQUEEN. Those varieties are protected under the European Union’s Community Plant Variety Rights legislation, which grants the breeders of novel plant varieties certain exclusive rights regarding the reproduction, commercialization, and distribution of propagating material of the varieties.

Plant Variety Rights InfringementActing upon information provided by Geslive, a plant breeders’ rights owners association, police searched the defendant’s greenhouses in 2006 and determined that he had been growing progeny plants of the protected varieties without authorization from the variety owner. The police discovered 200 square meters of HILTOPA plants and 2,400 square meters of carnations of the HILQUEEN variety. The exact quantity of WESTDIAMOND variety carnations could not be determined because the plants had either been removed from production or relocated to a different greenhouse.

Article 274.3 of the Spanish Penal Code provides for criminal punishment of up to six months’ imprisonment for certain violations of the rights of registered plant variety owners. News articles report that in the summer of 2014, a court in the city of Granada sentenced the manager of a seed company from Alpujarra to a six-month prison term for plant variety rights infringement. See Rafa Villegas, La Justicia castiga con 6 meses de cárcel a un empresario por reproducir judías protegidas, Frutas y Hortalizas de Almería (Jul. 2014) at 8. These cases follow a trend of recent years in which courts have meted out a number of prison sentences under article 274.3. See In Spain, Plant Breeders’ Rights Criminal Cases Draw Fines, Jail Terms, Acquittal, SullivanLawNet (Oct. 8, 2012); In Spain, Yet Another Jail Sentence For Plant Variety Rights Infringement, SullivanLawNet (Oct. 11, 2012).

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Ecuador: Change Constitution to Protect Traditional Knowledge


Ecuador map

Ecuador’s national government has proposed to amend the country’s constitution to provide special protections against the misappropriation of traditional knowledge and biological diversity. Propuesta de enmiendas constitucionales sobre la protección de los Saberes Ancestrales y la Biodiversidad del Ecuador, Secretaría de Educación Superior, Ciencia, Tecnología e Innovación (1 Sept. 2014).

The Ministry of Higher Education, Science, Technology and Innovation (known by the Spanish acronym Senescyt) concluded that current Ecuadorian law is inadequate to protect the ancestral knowledge of indigenous communities, as well as genetic resources within the country’s borders, against unscrupulous commercial exploitation by foreigners. With the aim of curbing such practices, Senescyt has proposed to amend articles 57 (rights of indigenous communities), 322 (intellectual property, collective knowledge, and genetic resources), and 402 (products derived from collective knowledge regarding biodiversity) of the 2008 Constitution of the Republic.

In a press release, René Ramírez, Minister of Senescyt, explained that,

Traditional knowledge is collective property that forms part of the system of human rights. Traditional knowledge and biodiversity are imprescriptible, indefeasible, and inalienable, and they are not patentable.

Ramírez emphasized that the government must create mechanisms for prevention, regulation, control, and sanctions because “at the moment we cannot do anything with regard to biopiracy because foreign researchers come [here], take the knowledge, make an innovation, and patent it outside the country.”

logo of UNASURAccording to the Senescyt press release, the proposed constitutional reforms would give indigenous communities the ability, through free and informed prior consent, to grant third parties access to their traditional knowledge in exchange for a just and equitable share of benefits. The release quoted María Inés Rivadeneira, the ministry’s Ancestral Knowledge Coordinator, as saying that the amendments were proposed following a meeting of the South American Council of Science, Technology, and Innovation of the Union of South American Nations (UNASUR), which discussed plans for a regional system of protection against biopiracy. According to Ms. Rivadeneira, the system would involve international monitoring to prevent overseas patenting, to commence legal actions against persons and institutions that inappropriately access biodiversity and traditional knowledge, and to establish a “blacklist” of the nations most guilty of biopiracy.

image of René Ramírez, Minister of Higher Education, Science, Technology and Innovation
René Ramírez, Minister of Senescyt

Mr. Ramírez can be heard explaining the need for the proposed constitutional amendments in an audio interview available here.


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Australian Full Federal Court Upholds Myriad Gene Patent

an image of the Federal CourtToday, in D’Arcy v Myriad Genetics Inc [2014] FCAFC 115, the Full Court of the Federal Court of Australia upheld the validity of Myriad Genetics’s Australian patent on methods and materials relating to the human  gene known as BRCA1.

THE BRCA1 GENE. Certain mutant alleles of the BRCA1 gene cause a predisposition to breast and ovarian cancer. Among other things, Myriad’s patent affords Myriad exclusive rights over a molecular diagnostic test that it developed to detect the presence of the BRCA1 gene and thereby to indicate whether an individual has an increased susceptibility to cancer.

an image of the DNA double helix

ISOLATED DNA. Claim 1 of the Myriad patent applies to “isolated” nucleic acid sequences corresponding to the relevant BRCA1 DNA mutations and polymorphisms. An “isolated” DNA sequence is one that has been removed from its normal cellular environment. Isolation is typically performed by cell lysis–bursting of the cell membrane or the nuclear membrane in order to release the DNA and RNA from inside–followed by chemical treatment to separate proteins from nucleic acids, centrifugation, and the application of enzymes to break down RNA and leave only purified DNA. The isolation process does not alter the sequence of nucleic acids; each strand contains both the protein-encoding “exons” and the non-coding “introns” as they existed in the cell prior to isolation. In this respect, DNA that has been isolated by extraction from a cell differs from synthetically-produced cDNA, which contains only exons and whose exact sequences are not found in nature.

ARGUMENTS AGAINST VALIDITY OF THE PATENTThe Myriad patent’s opponents, cancer survivor Yvonne D’Arcy and the group Cancer Voices Australia, contended that isolated nucleic acid is not materially different from cellular nucleic acid and that naturally occurring DNA and RNA, even in isolated form, are products of nature that cannot form the bases of a valid patent. The Full Court rejected this reasoning. In particular, the Full Court found inapposite a 2013 decision of the U.S. Supreme Court, which invalidated certain claims of a closely related U.S. patent owned by Myriad on the ground that isolated nucleic acid is a “product of nature” and thus is not patentable subject matter under U.S. patent law. See US Supreme Ct: Naturally Occurring DNA is Unpatentable Product of Nature, SullivanLawNet (13 June 2013).

AN “ARTIFICIALLY CREATED STATE OF AFFAIRS.” Observing that the Australian patent legislation differs from the U.S. Patent Act, the Australian court opined that it is unhelpful under the Australian legal regime to employ terms such as “the work of nature” or “the laws of nature” as a basis for denying a patent. “In Australia,” the court observed, “there is no statutory or jurisprudential limitation of patentability to exclude ‘products of nature.'” Instead, the court explained, the patentability analysis “should focus on differences in structure and function effected by the intervention of man and not on the similarities.” According to the Full Court, the key inquiry “is whether it consists of an artificially created state of affairs, not whether it produces or fails to produce an artificial effect.” The court concluded that the isolated nucleotide sequences claimed by Myriad did constitute such a state of affairs and as such were patentable. It wrote:

The isolated nucleic acid … has resulted in an artificially created state of affairs for economic benefit. The claimed product is properly the subject of letters patent. The claim is to an invention within the meaning of s 18(1) of the Act.

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Guatemalan Congress Repeals Plant Variety Rights Law

Guatemala's Congress of the Republic in Session on September 4, 2014Today the Congress of the Republic of Guatemala voted to repeal in its entirety the Law for the Protection of Plant Variety Rights that it approved less than three months ago. Congreso de la República aprueba de urgencia nacional derogatoria del Decreto 19-2014, Congreso de la Republica (4 Sept. 2014)

When Guatemala became a signatory to the Central America-Dominican Republic Free Trade Agreement, it agreed to accede to or ratify the 1991 Act of the International Convention for the Protection of Plant Varieties (the UPOV Convention). The UPOV Convention requires member states to grant plant variety rights (also known as plant breeders’ rights or plant variety protection)–a special form of intellectual property rights–to persons who breed new varieties of plants that are distinct, uniform, and stable.

The Law for the Protection of Plant Varieties, enacted with 82 votes on June 10, 2014, represented Guatemala’s effort to enact UPOV-compliant legislation. The law granted plant breeders exclusive rights–for 25 years in the case of trees and vines and 20 years for other plant species–regarding the marketing, sale, and other commercial acts relating to seeds of novel plant varieties registered with the government.

Legislators  passed the plant variety rights law without a prior public debate. At the time, national attention was focused on the 2014 World Cup, which was underway in Brazil. However, shortly after the law was enacted, lawmakers came under intense pressure to reform or repeal the measure.  A variety of labor unions, indigenous community organizations, and other critics opposed to the law expressed fears that it would lead to the privatization of the national seed supply, concentration of agricultural production in the hands of multinational companies, erosion of food sovereignty, and the disruption of traditional and indigenous farming practices. Campesinos guatemaltecos lograron derogación de ley Monsanto, Telesur (4 Sept. 2014). In protests against the legislation earlier this week, demonstrators closed sections of the Pan-American Highway, one of the country’s central transportation arteries. Guatemalan Protesters Demand Repeal of Plant Variety Rights Law, SullivanLawNet (2 Sept. 2014).

A press release posted on the official website of the Congress characterized the decision of the 117 congressmen and congresswomen who voted to repeal the law as an action for “the common good of the Guatemalan population.” According to one news source, Congressman Flavio José Yojcom García voted in favor of the law in June but supported its repeal today, explaining that “To err is human.” Presión social obliga al Congreso a derogar Ley de Vegetales, Prensa Libre (4 Sept. 2014).

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Guatemalan Protesters Demand Repeal of Plant Variety Rights Law

Guatemalan National FlagIn demonstrations today in Guatemala City, Guatemala, public officials and thousands of residents of indigenous communities demanded that the national legislature repeal the recently-enacted Plant Variety Rights Law. See Diputados se comprometen a derogar Ley Monsanto, Prensa Libre (2 Sept. 2014).. Although some members of congress opined publicly that passage of the legislation had been a mistake, lawmakers failed to reach the quorum necessary to reconsider the new law. Apparently many legislators were impeded from reaching the Congress because opponents of the law also blocked portions of the Pan-American Highway as part of their demonstration. Pobladores bloquean ruta para exigir derogación de Ley Monsanto, Prensa Libre (2 Sept. 2014). Late in the afternoon, Arístides Crespo, president of the Congreso de la República, promised to convene lawmakers tomorrow afternoon to consider repealing the law. 

"Anonymous" LogoToday the international network of Internet “hacktivists” claimed that, in support of the protest against what critics call the “Monsanto law,” it had shut down the official websites of Guatemala’s agriculture ministry, its constitutional court, and the national civilian police. Anonymous Guatemala se atribuye ataques a páginas oficiales, Prensa Libre (2 Sept. 2014).

Map of CAFTA-DR ParticipantsIn enacting the Plant Variety Rights Law earlier this year, Guatemala was following through on a commitment it made nine years ago in the Dominican Republic-Central America-United States Free Trade Agreement, to ratify or accede to the International Convention for the Protection of New Varieties of Plants (1991) (UPOV Convention 1991). The UPOV Convention establishes an international framework in which member states agree to grant patent-like rights to persons who breed new varieties of plants that are distinct, uniform, and stable. The Plant Variety Rights Law was scheduled to enter into effect later this month. However, on August 26, 2014, the Guatemalan Constitutional Court temporarily suspended the law’s effective date while it considers a constitutional challenge brought by a group of labor unions and farmers. See Expediente 3952-2014 (28-Ago-2014).

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Increased Fines for Violations of North Carolina Seed Law

North Carolina Map 3d ShapeIn 2013, the North Carolina legislature increased the maximum fine for violations of the state’s seed law from $500 to $10,000 per violation. See N.C. Session Law 2013-345, Senate Bill 455, An act to increase penalties for violation of the seed law. An article in neighboring South Carolina’s The State examines the primary reason for passage of the tough new law–unauthorized planting and sales of proprietary plant varieties. Martha Quillin, In North Carolina, a 20-fold increase in fines for seed piracy, The State (May 18, 2014).

As explained in an interview with North Carolina State University peanut breeder Dr. Tom Image of peanuts against background of fieldIsleib, even state universities depend heavily upon licensing revenues from crop varieties they develop, because public funds do not cover the high costs of research and development required to develop successful varieties. The federal Plant Variety Protection Act (PVPA) provides intellectual property protection for registered, proprietary plant varieties that are new, distinct, and uniform.  However, until last year, North Carolina’s state seed law did little to deter so-called “brown bagging”–unlawful sales of proprietary seed. The maximum fine available under the seed law was $500 per violation.

In 2012, it was discovered that a  North Carolina peanut seed distributor was selling large quantities of seed saved from his harvests, in unknowing violation of the law. Recognizing that the state law was ineffective to capture the attention of would-be brown bag sellers, the  North Carolina Seedsmen’s Association and state agricultural officials pushed for the harsher penalties. In addition to increasing applicable fines, the newly amended law also provides that in cases involving unlawful sales of seed protected under the PVPA, a court “shall order the payment of restitution to any injured party for any losses incurred as a result of the unlawful sale.”

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