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Bikram’s Yoga College of India, L.P. v. Evolation Yoga, LLC
United States Court of Appeals for the Ninth Circuit
803 F.3d 1032 (9th Cir. 2015)
Bikram Choudhury (plaintiff) immigrated from India to California to teach yoga. Drawing on hundreds of yoga poses that he had learned in his childhood, Choudhury selected 26 poses and 2 breathing exercises that he arranged into a special order called the Sequence. Choudhury began teaching 90-minute classes in a room set to 105 degrees using the Sequence and a specific series of instructions called the Dialogue. Choudhury published and copyrighted a book describing the Sequence’s poses and breathing exercises. Many years later, Choudhury registered the poses and breathing exercises contained in his book as a compilation with the U.S. Copyright Office. Choudhury also offered a course to train people who wished to become teachers. Mark Drost and Zefea Samson took Choudhury’s training course. After completing the course, Drost and Samson opened Evolation Yoga, LLC (Evolation) (defendant). Evolation offered a hot-yoga course that utilized 26 poses and 2 breathing exercises over the course of 90 minutes. Choudhury sued Evolation for copyright infringement, alleging that the Sequence was protected through his book’s copyright or, in the alternative, protected through his compilation’s copyright. Evolation moved for summary judgment. The district court held that the Sequence was a collection of facts and ideas and, for that reason, could not be copyrighted. The district court granted summary judgment to Evolation. Choudhury appealed.
Rule of Law
Holding and Reasoning (Wardlaw, J.)
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