L. Batlin & Son, Inc. v. Snyder

Uncle Sam mechanical banks were originally patented in 1886, but the patent ran out. The mechanical banks were made of metal and portrayed a man wearing a stovepipe hat, star-spangled vest, and red-and-white trousers, standing with a carpetbag next to his feet. A coin was placed in the man’s hand and then dropped into the carpetbag when a lever was pressed. There were certain recognizable symbols on the figure, such as an eagle on the base holding an arrow in its talons. The Uncle Sam mechanical banks were widely produced and available after the patent’s expiration. Jeffrey Snyder (defendant) contracted with a company in Hong Kong to create a smaller version of the bank made of plastic and with some of the symbols changed. For instance, Snyder’s plastic figure had an eagle holding leaves instead of an arrow, because the arrow shape did not appear correctly when made of plastic and at a smaller size. Snyder obtained a copyright registration for his version of the Uncle Sam mechanical bank. L. Batlin & Son, Inc. (Batlin) (plaintiff) attempted to import Uncle Sam mechanical banks, but its shipment was refused entry into the United States by the U.S. Customs Service due to Snyder’s copyright registration. Batlin filed suit, seeking a declaration that Snyder’s copyright was invalid. The district court granted Batlin a preliminary injunction. Snyder appealed.