King v. Mister Maestro, Inc.

Dr. Martin Luther King Jr. (plaintiff) was a clergyman and prominent leader in the US civil-rights movement. In June 1963, Dr. King delivered a speech in Detroit, Michigan. In August 1963, Dr. King delivered his famous “I Have a Dream” speech during a march for civil rights in Washington, DC, which included some of the words and ideas from the June speech. On the morning of the August speech, and at the request of the organizers of the event, Dr. King gave a copy of the planned speech to members of the press. Dr. King did not give a copy to anyone outside of the press. Later that day, Dr. King delivered the “I Have a Dream” speech in front of around 200,000 people. Thereafter, the speech was widely discussed in the press media, including being published in newspapers and broadcast on television and radio. Mister Maestro, Incorporated and 20th Century-Fox Record Corporation (the record companies) (defendants) also made and sold phonograph sound recordings of Dr. King’s speech without Dr. King’s consent and without paying any royalties. In September 1963, Dr. King registered a copyright on his speech, and in October 1963, he filed suit against the record companies for copyright infringement. The record companies argued, in part, that—because Dr. King’s speech had been delivered to such a large audience—the delivery was a general publication that had placed the speech within the public domain.