Art and Industry: The Mazer v. Stein Copyright Showdown
by Legal PDFOctober 7th, 2023
Too Long; Didn't Read
In the case of Mazer v. Stein, respondents were involved in crafting electric lamps, using original sculptural works as the basis for statuettes. These statuettes served as bases for fully equipped electric lamps, which they sold. Respondents sought copyright registration for the statuettes as "works of art" or reproductions thereof. The Supreme Court affirmed that the statuettes were indeed copyrightable. The decision highlighted that the legislative history and practice of the Copyright Office supported the copyrightability of such statuettes. It also emphasized that the potential patentability of the statuettes did not negate their eligibility for copyright protection. The court clarified that the intended or actual use of an article in industry does not invalidate its copyright registration. Additionally, registering a work of art published as part of a manufactured item was not considered a misuse of copyright. This ruling upheld the Court of Appeals' decision and settled the copyright dispute.
Mazer v. Stein, 347 U.S Court Filing, retrieved on September 27, 2023, is part of HackerNoon’s Legal PDF Series. You can jump to any part in this filing here. This part is 1 of 3.
Introduction
Respondents are engaged in the manufacture and sale of electric lamps. One of the respondents created original works of sculpture, from the models of which china statuettes were made. The statuettes were used as bases for fully equipped electric lamps, which respondents sold. Respondents submitted the statuettes, without ariy lamp components added, for registration under the copyright law as "works of art" or reproductions thereof. Held: The statuettes were copyrightable.. Pp. 202-219.
(a) The successive Copyright Acts, the legisfative history of the 1909 Act, and the practice of the Copyright Office show that "works of art" and "reproductions of works of art" were intended by Congress to include the authority to copyright such statuettes. Pp. 208-214.
(b) That the statuettes, fitted as lamps or unfitted, may be patentable does not bar their copyright as works of art. Pp. 215-217.
(c) The intended or actual use in industry of an article eligible for- copyright does not bar or invalidate its registration. P. 218.
(d) The subsequent registration of a work of art published as an element in a manufactured article is not a misuse of the copyright. Pp. 218-219.
204 F. 2d 472, affirmed
Respondenfts sued petitioners for eopyright infringement, and the District Court dismissed the complaint. 111 F. Supp. 359. The Court of Appeals reversed. 204 F. 2d 472. This Court granted certiorari. 346 U. S. 811. Affirmed, p. 219.
Max R. Kraus and Robert L. Kahn argued the cause and filed a brief for petitioners.
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This court case No. 228 retrieved on September 27, 2023, from tile.loc.gov is part of the public domain. The court-created documents are works of the federal government, and under copyright law, are automatically placed in the public domain and may be shared without legal restriction.
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