Lotus Development Corporation v. Borland International, Inc.

PETITIONER: Lotus Development Corporation
RESPONDENT: Borland International, Inc.
LOCATION: Seminole Tribe

DOCKET NO.: 94-2003
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the First Circuit

CITATION: 516 US 233 (1996)
ARGUED: Jan 08, 1996
DECIDED: Jan 16, 1996

ADVOCATES:
Gary L. Reback - on behalf of the Respondent
Henry B. Gutman - on behalf of the Petitioner

Facts of the case

Lotus Development Corporation (Lotus) copyrighted a computer spreadsheet program called Lotus 1-2-3. The program's menu options were arranged in a specific menu command hierarchy. Lotus 1-2-3 also allowed users to write "macros," which designate a certain series of commands to be executed with a single keystroke. Competing software-company Borland International, Inc. (Borland) released a similar program called Quattro that contained a program called "Key Reader." Lotus claimed that Key Reader infringed on its copyright because it copied Lotus 1-2-3 macros and arranged them according to the Lotus 1-2-3 menu command hierarchy. Borland explained that it did this to allow users already familiar with Lotus 1-2-3 to also operate Quattro and argued that the Lotus menu command hierarchy did not constitute copyright-protected material.

After the District Court ruled in favor of Lotus, Borland appealed to the U.S. Court of Appeals for the First Circuit. The First Circuit reversed, holding that the command menu hierarchy was a "method of operation" - a category excluded from copyright protection under 17 U.S.C.102(b).

Question

Is a computer program's menu command hierarchy a "method of operation" under 17 U.S.C.102(b), and therefore uncopyrightable?

Media for Lotus Development Corporation v. Borland International, Inc.

Audio Transcription for Oral Argument - January 08, 1996 in Lotus Development Corporation v. Borland International, Inc.

Audio Transcription for Opinion Announcement - January 16, 1996 in Lotus Development Corporation v. Borland International, Inc.

William H. Rehnquist:

I have the opinion of the Court to announce in No. 94-2003, Lotus Development Corporation versus Borland International.

The judgment of the Court of Appeals is affirmed by an equally divided court.

Justice Stevens took no part in the consideration or decision of this case.