Baker v. Selden

Citation: 101 U.S. 99 (1879)

Court: The Supreme Court of the United States of America

Bench: Justice Morrison Waite, Justice Nathan Clifford, Justice Noah H. Swayne, Justice Samuel F. Miller, Justice Stephen J. Field, Justice William Strong, Justice Joseph P. Bradley, Justice Ward Hunt, and Justice John M. Harlan

Facts:

Selden was the author of a book called “Selden's Condensed Ledger, or Book-keeping Simplified”. It was published in 1859 and rightful copyrights were registered for the same. This work contained a new system of book-keeping. Selden also held the copyrights for future improvements made to this system. In total, Selden had authored 6 such books. These books explained the system and the reasoning behind it. Baker had used a similar system in his books, but the tables used had different headings and column arrangements.

Issues:

Whether Baker had infringed copyrights held by Selden?

Laws Involved:

Copyright Act in the US jurisdiction prior to 1859.

Analysis:

The court looked at the evidence presented by both sides and decided in favor of Baker. They did not find Baker's usage to be violative of copyright held by Selden. It was held to be true that Baker did use the system mentioned in Selden’s book, but that alone was not enough to prove infringement.

The Court emphasized that if this type of use was held to be infringing, then the copyright owner could potentially stop others from using the book-keeping system mentioned in the book; and that would be a counter the purpose of copyright law protection.

Conclusion:

This judgment established an important principle of the present copyright law. The aspect of the “idea-expression dichotomy” was fortified through this case law. Copyright protection is provided only to the expression of an idea and not the idea itself. Therefore, in this case, protection was awarded to the expression made by Selden in his 6 books and not the system of book-keeping mentioned in his books.