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Nutt v. National Institute Incorporated for the Improvement of Memory
United States Court of Appeals for the Second Circuit
31 F.2d 236 (1929)
The author of a lecture series called “How to Improve Memory” copyrighted the lectures and assigned the copyright to an organization, the National Institute Incorporated for the Improvement of Memory (the institute) (plaintiff), in which he was a partner. Robert H. Nutt (defendant) worked with the institute before leaving to conduct his own series of memory-improvement lectures. Nutt’s lectures used ideas gleaned from his time with the institute, but changes were made to the order and manner in which those ideas were presented. The institute brought a copyright-infringement action in federal district court, which found in favor of the institute. Nutt appealed, arguing that the “How to Improve Memory” author dedicated his work to the public by delivering the lectures prior to copyrighting them. The United States Court of Appeals for the Second Circuit granted certiorari.
Rule of Law
Holding and Reasoning (Manton, J.)
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