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Mazer v. Stein

Mazer v. Stein
347 U.S. 201 (1954)

FACTS
Stein created and registered for copyright a Grecian-style sculpture of a woman, which was then manufactured into a mass-produced lamp base.
Mazer subsequently manufactured similar lamp bases.

PROCEUDRE
Stein filed action for copyright infringement. The trial court found for Mazer on the grounds that copyrights are not intended to protect utilitarian items such as lamps, resulting in an appeal by Stein. The appellate court reversed, finding that a subsequent utilization of a work of art in an article of manufacture does not preclude the copyright owner to be protected from the infringement of the work itself. Mazer appeals.

ISSUE
Whether Stein is entitled to copyright protection from Mazer’s copy of the lamp base because the lamp statute qualifies as a “work of art” under U.S Copyright Law?

HOLDING
Yes.

REASONING

Upon reviewing the history of the successive Copyright Acts and the legislative history, the Court found that a “work of art” has a broader specification than just a “work of fine art.” A work that is the result of the original, tangible ideas of the creator is subject to copyright protection. Thus, the Court finds that the lamp base satisfies the requisite originality needed for protection.

The Court also reasons that the lamp base, fitted as lamps or unfitted, may be granted a deign patent but patentability does not bar the lamp bases from being copyrighted as a “work of art. Furthermore, the Court found that the intended or actual use in industry of an article eligible for copyright does not bar or invalidate its registration. As a result, Stein’s lamp base is entitled to copyright protection.

RULE OF LAW
An original idea, incorporated into an utilitarian object, may be protected as a “work of art” under U.S. Copyright Law.

POLICY
The Court based its decision on the policy reasoning that copyrights are granted (1) to encourage individual effort by personal gain and (2) to promote advancement of public welfare through talents of authors and inventors in science and art.

DISPOSITION
Copyright protection granted to Stein.


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Page last modified on Monday 25 of October, 2010 23:27:22 GMT by ilizewski.
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