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Andrien v. Southern Ocean County Chamber of Commerce

927 F.2d 132 (1991)

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Andrien v. Southern Ocean County Chamber of Commerce

United States Court of Appeals for the Third Circuit
927 F.2d 132 (1991)

Facts

Real estate agent James Andrien (plaintiff) found that the maps of Long Beach Island, New Jersey, distributed by the Southern Ocean County Chamber of Commerce (the chamber of commerce) (defendant) were inadequate. Andrien compiled several existing maps and undertook a personal survey of Long Beach Island to create a new, more complete map. Andrien assigned an employee, Carolyn Haines, to perform the work of scaling down the map to a commercially usable size. Andrien was sometimes present when Haines performed this work. Andrien obtained a copyright on the finished product. The chamber of commerce then allegedly distributed unauthorized copies of the new map. Andrien brought a copyright-infringement suit in federal district court, where he sought a preliminary injunction. The court granted summary judgment in favor of the chamber of commerce, holding that Haines rather than Andrien was the true author. Andrien appealed. The United States Court of Appeals for the Third Circuit granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Weis, J.)

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