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Lotus Development Corp. v. Borland International

United States Court of Appeals for the First Circuit
49 F.3d 807 (1st Cir. 1996)


Facts

Lotus Development Corp. (Lotus) (plaintiff) developed a computer menu command hierarchy that allowed users to operate Lotus’s computer spreadsheet program, called Lotus 1-2-3. Specifically, the hierarchy allowed users to enter a command, such as “copy” or “print,” and the program would carry out the corresponding function. It was not possible to operate Lotus 1-2-3 without the hierarchy. Borland International (Borland) (defendant) copied Lotus’s menu command hierarchy to create its own computer program. Lotus brought suit against Borland for copyright infringement. The United States District Court for the District of Massachusetts (District Court) held that Borland infringed on Lotus’s copyright because Lotus’s command terms could be easily be altered (i.e., “quit” could easily be called “exit) with no change in functionality. As a result, according to the District Court, Lotus’s arrangement and naming of its menu tree was copyrightable. Borland appealed.

Rule of Law

Issue

Holding and Reasoning (Stahl, J.)

Concurrence (Boudin, J.)

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