Lotus v. Borland

Case Date: 03/09/1995
Court: United States Court of Appeals
Docket No: 93-2214



April 19, 1995
United States Court of Appeals United States Court of Appeals
For the First Circuit For the First Circuit
____________________

No. 93-2214

LOTUS DEVELOPMENT CORPORATION,

Plaintiff, Appellee,

v.

BORLAND INTERNATIONAL, INC.,

Defendant, Appellant.

____________________

ERRATA SHEET ERRATA SHEET
The opinion of this court issued on March 9, 1995, is amended as

follows:

On page 38, line 16: Change "See id. at 562." to "See id. at ________ _______

562. But see Campbell v. Acuff-Rose Music, Inc., 114 S. Ct. 1164, ________ ________ ______________________

1174 (1994)."




United States Court of Appeals United States Court of Appeals

For the First Circuit For the First Circuit

____________________

No. 93-2214

LOTUS DEVELOPMENT CORPORATION,

Plaintiff, Appellee,

v.

BORLAND INTERNATIONAL, INC.,

Defendant, Appellant.

____________________

APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Robert E. Keeton, U.S. District Judge] ___________________

____________________

Before

Torruella, Chief Judge, ___________

Boudin and Stahl, Circuit Judges. ______________

____________________

Gary L. Reback, with whom Peter N. Detkin, Michael Barclay, ________________ _________________ ________________

Isabella E. Fu, Wilson Sonsini Goodrich & Rosati, Peter E. Gelhaar, _______________ _________________________________ ________________

Katherine L. Parks, and Donnelly Conroy & Gelhaar, were on brief for ___________________ __________________________

appellant.

Matthew P. Poppel, et. al, were on brief for Computer Scientists, _________________

amicus curiae.

Dennis S. Karjala and Peter S. Menell on brief, amici curiae. _________________ _______________

Jeffrey C. Cannon and Baker Keaton Seibel & Cannon were on brief __________________ _____________________________

for Computer Software Industry Association, amicus curiae.

Laureen E. McGurk, David A. Rabin, Bryan G. Harrison and Morris __________________ ______________ __________________ ______

Manning & Martin were on brief for Chicago Computer Society, Diablo _________________

Users Group, Danbury Area Computer Society, IBM AB Users Group,

Kentucky-Indiana Personal Computer Users Group, Long Island PC Users

Group, Napa Valley PC Users Group, Pacific Northwest PC Users Group,

Palmetto Personal Computer Club, Philadelphia Area Computer Society,

Inc., Phoenix IBM PC Users Group, Pinellas IBM PC Users Group, Quad

Cities Computer Society, Quattro Pro Users Group, Sacramento PC Users

Group, San Francisco PC Users Group, Santa Barbara PC Users Group,

Twin Cities PC Users Group, and Warner Robbins Personal Computer

Association, amici curiae.

Diane Marie O'Malley and Hanson Bridgett Marcus Vlahos & Rudy _____________________ _______________________________________

were on brief for Software Entrepreneurs' Forum, amicus curiae.

Peter M.C. Choy was on brief for American Committee for _________________

Interoperable Systems, amicus curiae.

Howard B. Abrams, Howard C. Anawalt, Stephen R. Barnett, Ralph S. ________________ _________________ __________________ ________

Brown, Stephen L. Carter, Amy B. Cohen, Paul J. Heald, Peter A. Jaszi, _____ _________________ ____________ _____________ ______________

John A. Kidwell, Edmund W. Kitch, Roberta R. Kwall, David L. Lange, ________________ ________________ _________________ ______________

Marshall Leaffer, Jessica D. Litman, Charles R. McManis, L. Ray _________________ __________________ ____________________ ______

Patterson, Jerome H. Reichman, David A. Rice, Pamela Samuelson, David _________ __________________ ______________ ________________ _____

J. Seipp, David E. Shipley, Lionel S. Sobel, Alfred C. Yen, and Diane ________ ________________ _______________ _____________ _____

L. Zimmerman were on brief for Copyright Law Professors, amicus _____________

curiae.

Henry B. Gutman, with whom Kerry L. Konrad, Joshua H. Epstein, ________________ ________________ _________________

Kimberly A. Caldwell, O'Sullivan Graev & Karabell, Thomas M. Lemberg, ____________________ ___________________________ __________________

James C. Burling, and Hale and Dorr, were on brief for appellee. ________________ _____________

Morton David Goldberg, June M. Besek, David O. Carson, Jesse M. ______________________ _____________ ________________ ________

Feder, Schwab Goldberg Price & Dannay, and Arthur R. Miller were on _____ _______________________________ _________________

brief for Apple Computer, Inc., Digital Equipment Corporation,

International Business Machines Corporation, and Xerox Corporation,

amici curiae.

Jon A. Baumgarten, Proskauer Rose Goetz & Mendelsohn, and Robert _________________ ___________________________________ ______

A. Gorman were on brief for Adobe Systems, Inc., Apple Computer, Inc., _________

Computer Associates International, Inc., Digital Equipment

Corporation, and International Business Machines Corporation, amici

curiae.

Herbert F. Schwartz, Vincent N. Palladino, Susan Progoff, Fish & ____________________ _____________________ _____________ ______

Neave, William J. Cheeseman, and Foley Hoag & Eliot, were on brief for _____ ____________________ __________________

Computer and Business Equipment Manufacturers Association, amicus

curiae.

_____________________

March 9, 1995

_____________________





STAHL, Circuit Judge. This appeal requires us to STAHL, Circuit Judge. ______________

decide whether a computer menu command hierarchy is

copyrightable subject matter. In particular, we must decide

whether, as the district court held, plaintiff-appellee Lotus

Development Corporation's copyright in Lotus 1-2-3, a

computer spreadsheet program, was infringed by defendant-

appellant Borland International, Inc., when Borland copied

the Lotus 1-2-3 menu command hierarchy into its Quattro and

Quattro Pro computer spreadsheet programs. See Lotus Dev. ___ __________

Corp. v. Borland Int'l, Inc., 788 F. Supp. 78 (D. Mass. 1992) _____ ___________________

("Borland I"); Lotus Dev. Corp. v. Borland Int'l, Inc., 799 _________ _________________ ____________________

F. Supp. 203 (D. Mass. 1992) ("Borland II"); Lotus Dev. Corp. __________ ________________

v. Borland Int'l, Inc., 831 F. Supp. 202 (D. Mass. 1993) ____________________

("Borland III"); Lotus Dev. Corp. v. Borland Int'l, Inc., 831 ___________ ________________ ___________________

F. Supp. 223 (D. Mass. 1993) ("Borland IV"). __________

I. I. __

Background Background __________

Lotus 1-2-3 is a spreadsheet program that enables

users to perform accounting functions electronically on a

computer. Users manipulate and control the program via a

series of menu commands, such as "Copy," "Print," and "Quit."

Users choose commands either by highlighting them on the

screen or by typing their first letter. In all, Lotus 1-2-3

-3- 3

has 469 commands arranged into more than 50 menus and

submenus.

Lotus 1-2-3, like many computer programs, allows

users to write what are called "macros." By writing a macro,

a user can designate a series of command choices with a

single macro keystroke. Then, to execute that series of

commands in multiple parts of the spreadsheet, rather than

typing the whole series each time, the user only needs to

type the single pre-programmed macro keystroke, causing the

program to recall and perform the designated series of

commands automatically. Thus, Lotus 1-2-3 macros shorten the

time needed to set up and operate the program.

Borland released its first Quattro program to the

public in 1987, after Borland's engineers had labored over

its development for nearly three years. Borland's objective

was to develop a spreadsheet program far superior to existing

programs, including Lotus 1-2-3. In Borland's words, "[f]rom

the time of its initial release . . . Quattro included

enormous innovations over competing spreadsheet products."

The district court found, and Borland does not now

contest, that Borland included in its Quattro and Quattro Pro

version 1.0 programs "a virtually identical copy of the ____________________

entire 1-2-3 menu tree." Borland III, 831 F. Supp. at 212 ___________

(emphasis in original). In so doing, Borland did not copy

any of Lotus's underlying computer code; it copied only the

-4- 4

words and structure of Lotus's menu command hierarchy.

Borland included the Lotus menu command hierarchy in its

programs to make them compatible with Lotus 1-2-3 so that

spreadsheet users who were already familiar with Lotus 1-2-3

would be able to switch to the Borland programs without

having to learn new commands or rewrite their Lotus macros.

In its Quattro and Quattro Pro version 1.0

programs, Borland achieved compatibility with Lotus 1-2-3 by

offering its users an alternate user interface, the "Lotus

Emulation Interface." By activating the Emulation Interface,

Borland users would see the Lotus menu commands on their

screens and could interact with Quattro or Quattro Pro as if

using Lotus 1-2-3, albeit with a slightly different looking

screen and with many Borland options not available on Lotus

1-2-3. In effect, Borland allowed users to choose how they

wanted to communicate with Borland's spreadsheet programs:

either by using menu commands designed by Borland, or by

using the commands and command structure used in Lotus 1-2-3

augmented by Borland-added commands.

Lotus filed this action against Borland in the

District of Massachusetts on July 2, 1990, four days after a

district court held that the Lotus 1-2-3 "menu structure,

taken as a whole -- including the choice of command terms

[and] the structure and order of those terms," was protected

expression covered by Lotus's copyrights. Lotus Dev. Corp. ________________

-5- 5

v. Paperback Software Int'l, 740 F. Supp. 37, 68, 70 (D. _________________________

Mass. 1990) ("Paperback").1 Three days earlier, on the _________

morning after the Paperback decision, Borland had filed a _________

declaratory judgment action against Lotus in the Northern

District of California, seeking a declaration of non-

infringement. On September 10, 1990, the district court in

California dismissed Borland's declaratory judgment action in

favor of this action.

Lotus and Borland filed cross motions for summary

judgment; the district court denied both motions on March 20,

1992, concluding that "neither party's motion is supported by

the record." Borland I, 788 F. Supp. at 80. The district _________

court invited the parties to file renewed summary judgment

motions that would "focus their arguments more precisely" in

light of rulings it had made in conjunction with its denial

of their summary judgment motions. Id. at 82. Both parties ___

filed renewed motions for summary judgment on April 24, 1992.

In its motion, Borland contended that the Lotus 1-2-3 menus

were not copyrightable as a matter of law and that no

reasonable trier of fact could find that the similarity

between its products and Lotus 1-2-3 was sufficient to

sustain a determination of infringement. Lotus contended in
____________________

1. Judge Keeton presided over both the Paperback litigation _________
and this case.

-6- 6

its motion that Borland had copied Lotus 1-2-3's entire user

interface and had thereby infringed Lotus's copyrights.

On July 31, 1992, the district court denied

Borland's motion and granted Lotus's motion in part. The

district court ruled that the Lotus menu command hierarchy

was copyrightable expression because

[a] very satisfactory spreadsheet menu
tree can be constructed using different
commands and a different command
structure from those of Lotus 1-2-3. In
fact, Borland has constructed just such
an alternate tree for use in Quattro
Pro's native mode. Even if one holds the
arrangement of menu commands constant, it
is possible to generate literally
millions of satisfactory menu trees by
varying the menu commands employed.

Borland II, 799 F. Supp. at 217. The district court ___________

demonstrated this by offering alternate command words for the

ten commands that appear in Lotus's main menu. Id. For ___

example, the district court stated that "[t]he `Quit' command

could be named `Exit' without any other modifications," and

that "[t]he `Copy' command could be called `Clone,' `Ditto,'

`Duplicate,' `Imitate,' `Mimic,' `Replicate,' and

`Reproduce,' among others." Id. Because so many variations ___

were possible, the district court concluded that the Lotus

developers' choice and arrangement of command terms,

reflected in the Lotus menu command hierarchy, constituted

copyrightable expression.

-7- 7

In granting partial summary judgment to Lotus, the

district court held that Borland had infringed Lotus's

copyright in Lotus 1-2-3:

[A]s a matter of law, Borland's Quattro
products infringe the Lotus 1-2-3
copyright because of (1) the extent of
copying of the "menu commands" and "menu
structure" that is not genuinely disputed _________
in this case, (2) the extent to which the
copied elements of the "menu commands"
and "menu structure" contain expressive
aspects separable from the functions of
the "menu commands" and "menu structure,"
and (3) the scope of those copied
expressive aspects as an integral part of
Lotus 1-2-3.

Borland II, 799 F. Supp. at 223 (emphasis in original). The __________

court nevertheless concluded that while the Quattro and

Quattro Pro programs infringed Lotus's copyright, Borland had

not copied the entire Lotus 1-2-3 user interface, as Lotus

had contended. Accordingly, the court concluded that a jury

trial was necessary to determine the scope of Borland's

infringement, including whether Borland copied the long

prompts2 of Lotus 1-2-3, whether the long prompts contained

____________________

2. Lotus 1-2-3 utilizes a two-line menu; the top line lists
the commands from which the user may choose, and the bottom
line displays what Lotus calls its "long prompts." The long
prompts explain, as a sort of "help text," what the
highlighted menu command will do if entered. For example,
the long prompt for the "Worksheet" command displays the
submenu that the "Worksheet" command calls up; it reads
"Global, Insert, Delete, Column, Erase, Titles, Window,
Status, Page." The long prompt for the "Copy" command
explains what function the "Copy" command will perform:
"Copy a cell or range of cells." The long prompt for the
"Quit" command reads, "End 1-2-3 session (Have you saved your
work?)."

-8- 8

expressive elements, and to what extent, if any, functional

constraints limited the number of possible ways that the

Lotus menu command hierarchy could have been arranged at the

time of its creation. See Borland III, 831 F. Supp. at 207. ___ ___________

Additionally, the district court granted Lotus summary

judgment on Borland's affirmative defense of waiver, but not

on its affirmative defenses of laches and estoppel. Borland _______

II, 799 F. Supp. at 222-23. __

Immediately following the district court's summary

judgment decision, Borland removed the Lotus Emulation

Interface from its products. Thereafter, Borland's

spreadsheet programs no longer displayed the Lotus 1-2-3

menus to Borland users, and as a result Borland users could

no longer communicate with Borland's programs as if they were

using a more sophisticated version of Lotus 1-2-3.

Nonetheless, Borland's programs continued to be partially

compatible with Lotus 1-2-3, for Borland retained what it

called the "Key Reader" in its Quattro Pro programs. Once

turned on, the Key Reader allowed Borland's programs to

____________________

Prior to trial, the parties agreed to exclude the
copying of the long prompts from the case; Lotus agreed not
to contend that Borland had copied the long prompts, Borland
agreed not to argue that it had not copied the long prompts,
and both sides agreed not to argue that the issue of whether
Borland had copied the long prompts was material to any other
issue in the case. See Borland III, 831 F. Supp. at 208. ___ ___________

-9- 9

understand and perform some Lotus 1-2-3 macros.3 With the

Key Reader on, the Borland programs used Quattro Pro menus

for display, interaction, and macro execution, except when

they encountered a slash ("/") key in a macro (the starting

key for any Lotus 1-2-3 macro), in which case they

interpreted the macro as having been written for Lotus 1-2-3.

Accordingly, people who wrote or purchased macros to shorten

the time needed to perform an operation in Lotus 1-2-3 could

still use those macros in Borland's programs.4 The district

court permitted Lotus to file a supplemental complaint

alleging that the Key Reader infringed its copyright.

The parties agreed to try the remaining liability

issues without a jury. The district court held two trials,

the Phase I trial covering all remaining issues raised in the

original complaint (relating to the Emulation Interface) and

the Phase II trial covering all issues raised in the

supplemental complaint (relating to the Key Reader). At the

Phase I trial, there were no live witnesses, although

considerable testimony was presented in the form of

affidavits and deposition excerpts. The district court ruled

upon evidentiary objections counsel interposed. At the Phase

____________________

3. Because Borland's programs could no longer display the
Lotus menu command hierarchy to users, the Key Reader did not
allow debugging or modification of macros, nor did it permit
the execution of most interactive macros.

4. See Borland IV, 831 F. Supp. at 226-27, for a more __________
detailed explanation of macros and the Key Reader.

-10- 10

II trial, there were two live witnesses, each of whom

demonstrated the programs for the district court.

After the close of the Phase I trial, the district

court permitted Borland to amend its answer to include the

affirmative defense of "fair use." Because Borland had

presented all of the evidence supporting its fair-use defense

during the Phase I trial, but Lotus had not presented any

evidence on fair use (as the defense had not been raised

before the conclusion of the Phase I trial), the district

court considered Lotus's motion for judgment on partial

findings of fact. See Fed. R. Civ. P. 52(c). The district ___

court held that Borland had failed to show that its use of

the Lotus 1-2-3 menu command hierarchy in its Emulation

Interface was a fair use. See Borland III, 831 F. Supp. at ___ ___________

208.

In its Phase I-trial decision, the district court

found that "each of the Borland emulation interfaces contains

a virtually identical copy of the 1-2-3 menu tree and that

the 1-2-3 menu tree is capable of a wide variety of

expression." Borland III, 831 F. Supp. at 218. The district ___________

court also rejected Borland's affirmative defenses of laches

and estoppel. Id. at 218-23. ___

In its Phase II-trial decision, the district court

found that Borland's Key Reader file included "a virtually

identical copy of the Lotus menu tree structure, but

-11- 11

represented in a different form and with first letters of

menu command names in place of the full menu command names."

Borland IV, 831 F. Supp. at 228. In other words, Borland's __________

programs no longer included the Lotus command terms, but only

their first letters. The district court held that "the Lotus

menu structure, organization, and first letters of the

command names . . . constitute part of the protectable

expression found in [Lotus 1-2-3]." Id. at 233. ___

Accordingly, the district court held that with its Key

Reader, Borland had infringed Lotus's copyright. Id. at 245. ___

The district court also rejected Borland's affirmative

defenses of waiver, laches, estoppel, and fair use. Id. at ___

235-45. The district court then entered a permanent

injunction against Borland, id. at 245, from which Borland ___

appeals.

This appeal concerns only Borland's copying of the

Lotus menu command hierarchy into its Quattro programs and

Borland's affirmative defenses to such copying. Lotus has

not cross-appealed; in other words, Lotus does not contend on

appeal that the district court erred in finding that Borland

had not copied other elements of Lotus 1-2-3, such as its

screen displays.

II. II. ___

Discussion Discussion __________

-12- 12

On appeal, Borland does not dispute that it

factually copied the words and arrangement of the Lotus menu

command hierarchy. Rather, Borland argues that it "lawfully

copied the unprotectable menus of Lotus 1-2-3." Borland

contends that the Lotus menu command hierarchy is not

copyrightable because it is a system, method of operation,

process, or procedure foreclosed from protection by 17 U.S.C.

102(b). Borland also raises a number of affirmative

defenses.



-13- 13

A. Copyright Infringement Generally ____________________________________

To establish copyright infringement, a plaintiff

must prove "(1) ownership of a valid copyright, and (2)

copying of constituent elements of the work that are

original." Feist Publications, Inc. v. Rural Tel. Serv. Co., ________________________ ____________________

499 U.S. 340, 361 (1991); see also Data Gen. Corp. v. Grumman ___ ____ _______________ _______

Sys. Support Corp., 36 F.3d 1147, 1160 n.19 (1st Cir. 1994); ___________________

Concrete Mach. Co. v. Classic Lawn Ornaments, Inc., 843 F.2d __________________ _____________________________

600, 605 (1st Cir. 1988). To show ownership of a valid

copyright and therefore satisfy Feist's first prong, a _____

plaintiff must prove that the work as a whole is original and

that the plaintiff complied with applicable statutory

formalities. See Engineering Dynamics, Inc. v. Structural ___ ___________________________ __________

Software, Inc., 26 F.3d 1335, 1340 (5th Cir. 1994). "In _______________

judicial proceedings, a certificate of copyright registration

constitutes prima facie evidence of copyrightability and ___________

shifts the burden to the defendant to demonstrate why the

copyright is not valid." Bibbero Sys., Inc. v. Colwell Sys., __________________ _____________

Inc., 893 F.2d 1104, 1106 (9th Cir. 1990); see also 17 U.S.C. ____ ___ ____

410(c); Folio Impressions, Inc. v. Byer California, 937 ________________________ ________________

F.2d 759, 763 (2d Cir. 1991) (presumption of validity may be

rebutted).

To show actionable copying and therefore satisfy

Feist's second prong, a plaintiff must first prove that the _____

alleged infringer copied plaintiff's copyrighted work as a

-14- 14

factual matter; to do this, he or she may either present

direct evidence of factual copying or, if that is

unavailable, evidence that the alleged infringer had access

to the copyrighted work and that the offending and

copyrighted works are so similar that the court may infer

that there was factual copying (i.e., probative similarity).

Engineering Dynamics, 26 F.3d at 1340; see also Concrete _____________________ ___ ____ ________

Mach., 843 F.2d at 606. The plaintiff must then prove that _____

the copying of copyrighted material was so extensive that it

rendered the offending and copyrighted works substantially

similar. See Engineering Dynamics, 26 F.3d at 1341. ___ ____________________

In this appeal, we are faced only with whether the

Lotus menu command hierarchy is copyrightable subject matter

in the first instance, for Borland concedes that Lotus has a

valid copyright in Lotus 1-2-3 as a whole5 and admits to

factually copying the Lotus menu command hierarchy. As a

result, this appeal is in a very different posture from most
____________________

5. Computer programs receive copyright protection as
"literary works." See 17 U.S.C. 102(a)(1) (granting ___
protection to "literary works") and 17 U.S.C. 101 (defining ___
"literary works" as "works . . . expressed in words, numbers,
or other verbal or numerical symbols or indicia, regardless
of the nature of the material objects, such as books,
periodicals, phonorecords, film, tapes, disks, or cards, in _____
which they are embodied" (emphasis added)); see also H.R. ___ ____
Rep. No. 1476, 94th Cong., 2d Sess. 54 (1976), reprinted in _________ __
1976 U.S.C.C.A.N. 5659, 5667 ("The term `literary works' . .
. includes computer data bases, and computer programs to the
extent that they incorporate authorship in the programmer's
expression of original ideas, as distinguished from the ideas
themselves.").

-15- 15

copyright-infringement cases, for copyright infringement

generally turns on whether the defendant has copied protected

expression as a factual matter. Because of this different

posture, most copyright-infringement cases provide only

limited help to us in deciding this appeal. This is true

even with respect to those copyright-infringement cases that

deal with computers and computer software.

B. Matter of First Impression ______________________________

Whether a computer menu command hierarchy

constitutes copyrightable subject matter is a matter of first

impression in this court. While some other courts appear to

have touched on it briefly in dicta, see, e.g., Autoskill, ___ ____ __________

Inc. v. National Educ. Support Sys., Inc., 994 F.2d 1476, ____ ___________________________________

1495 n.23 (10th Cir.), cert. denied, 114 S. Ct. 307 (1993), _____ ______

we know of no cases that deal with the copyrightability of a

menu command hierarchy standing on its own (i.e., without

other elements of the user interface, such as screen

displays, in issue). Thus we are navigating in uncharted

waters.

Borland vigorously argues, however, that the

Supreme Court charted our course more than 100 years ago when

it decided Baker v. Selden, 101 U.S. 99 (1879). In Baker v. _____ ______ _____

Selden, the Court held that Selden's copyright over the ______

textbook in which he explained his new way to do accounting

-16- 16

did not grant him a monopoly on the use of his accounting

system.6 Borland argues:

The facts of Baker v. Selden, and even _____ ______
the arguments advanced by the parties in
that case, are identical to those in this
case. The only difference is that the
"user interface" of Selden's system was
implemented by pen and paper rather than
by computer.

To demonstrate that Baker v. Selden and this appeal both _____ ______

involve accounting systems, Borland even supplied this court

with a video that, with special effects, shows Selden's paper

forms "melting" into a computer screen and transforming into

Lotus 1-2-3.

We do not think that Baker v. Selden is nearly as _____ ______

analogous to this appeal as Borland claims. Of course, Lotus

1-2-3 is a computer spreadsheet, and as such its grid of

horizontal rows and vertical columns certainly resembles an

accounting ledger or any other paper spreadsheet. Those

grids, however, are not at issue in this appeal for, unlike

Selden, Lotus does not claim to have a monopoly over its

accounting system. Rather, this appeal involves Lotus's

monopoly over the commands it uses to operate the computer.

Accordingly, this appeal is not, as Borland contends,

"identical" to Baker v. Selden. _____ ______

C. Altai _________
____________________

6. Selden's system of double-entry bookkeeping is the now
almost-universal T-accounts system.

-17- 17

Before we analyze whether the Lotus menu command

hierarchy is a system, method of operation, process, or

procedure, we first consider the applicability of the test

the Second Circuit set forth in Computer Assoc. Int'l, Inc. ____________________________

v. Altai, Inc., 982 F.2d 693 (2d Cir. 1992).7 The Second ____________

Circuit designed its Altai test to deal with the fact that _____

computer programs, copyrighted as "literary works," can be

infringed by what is known as "nonliteral" copying, which is

copying that is paraphrased or loosely paraphrased rather

than word for word. See id. at 701 (citing nonliteral- ___ ___

copying cases); see also 3 Melville B. Nimmer & David Nimmer, ___ ____

Nimmer on Copyright 13.03[A][1] (1993). When faced with ____________________

nonliteral-copying cases, courts must determine whether

similarities are due merely to the fact that the two works

share the same underlying idea or whether they instead

indicate that the second author copied the first author's

expression. The Second Circuit designed its Altai test to _____

deal with this situation in the computer context,

specifically with whether one computer program copied

nonliteral expression from another program's code.
____________________

7. We consider the Altai test because both parties and many _____
of the amici focus on it so heavily. Borland, in particular, _____
is highly critical of the district court for not employing
the Altai test. Borland does not, however, indicate how _____
using that test would have been dispositive in Borland's
favor. Interestingly, Borland appears to contradict its own
reasoning at times by criticizing the applicability of the
Altai test. _____

-18- 18

The Altai test involves three steps: abstraction, _____

filtration, and comparison. The abstraction step requires

courts to "dissect the allegedly copied program's structure

and isolate each level of abstraction contained within it."

Altai, 982 F.2d at 707. This step enables courts to identify _____

the appropriate framework within which to separate

protectable expression from unprotected ideas. Second,

courts apply a "filtration" step in which they examine "the

structural components at each level of abstraction to

determine whether their particular inclusion at that level

was `idea' or was dictated by considerations of efficiency,

so as to be necessarily incidental to that idea; required by

factors external to the program itself; or taken from the

public domain." Id. Finally, courts compare the protected ___

elements of the infringed work (i.e., those that survived the

filtration screening) to the corresponding elements of the

allegedly infringing work to determine whether there was

sufficient copying of protected material to constitute

infringement. Id. at 710. ___

In the instant appeal, we are not confronted with

alleged nonliteral copying of computer code. Rather, we are

faced with Borland's deliberate, literal copying of the Lotus

menu command hierarchy. Thus, we must determine not whether

nonliteral copying occurred in some amorphous sense, but

-19- 19

rather whether the literal copying of the Lotus menu command

hierarchy constitutes copyright infringement.

While the Altai test may provide a useful framework _____

for assessing the alleged nonliteral copying of computer

code, we find it to be of little help in assessing whether

the literal copying of a menu command hierarchy constitutes

copyright infringement. In fact, we think that the Altai _____

test in this context may actually be misleading because, in

instructing courts to abstract the various levels, it seems

to encourage them to find a base level that includes

copyrightable subject matter that, if literally copied, would

make the copier liable for copyright infringement.8 While

that base (or literal) level would not be at issue in a

nonliteral-copying case like Altai, it is precisely what is _____

at issue in this appeal. We think that abstracting menu

command hierarchies down to their individual word and menu

levels and then filtering idea from expression at that stage,

as both the Altai and the district court tests require, _____

obscures the more fundamental question of whether a menu

command hierarchy can be copyrighted at all. The initial

____________________

8. We recognize that Altai never states that every work _____
contains a copyrightable "nugget" of protectable expression.
Nonetheless, the implication is that for literal copying, "it
is not necessary to determine the level of abstraction at
which similarity ceases to consist of an `expression of
ideas,' because literal similarity by definition is always a
similarity as to the expression of ideas." 3 Melville B.
Nimmer & David Nimmer, Nimmer on Copyright 13.03[A](2) ____________________
(1993).

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inquiry should not be whether individual components of a menu

command hierarchy are expressive, but rather whether the menu

command hierarchy as a whole can be copyrighted. But see ___ ___

Gates Rubber Co. v. Bando Chem. Indus., Ltd., 9 F.3d 823 _________________ __________________________

(10th Cir. 1993) (endorsing Altai's abstraction-filtration- _____

comparison test as a way of determining whether "menus and

sorting criteria" are copyrightable).

D. The Lotus Menu Command Hierarchy: A "Method of _____________________________________________________________

Operation" __________

Borland argues that the Lotus menu command

hierarchy is uncopyrightable because it is a system, method

of operation, process, or procedure foreclosed from copyright

protection by 17 U.S.C. 102(b). Section 102(b) states:

"In no case does copyright protection for an original work of

authorship extend to any idea, procedure, process, system,

method of operation, concept, principle, or discovery,

regardless of the form in which it is described, explained,

illustrated, or embodied in such work." Because we conclude

that the Lotus menu command hierarchy is a method of

operation, we do not consider whether it could also be a

system, process, or procedure.

We think that "method of operation," as that term

is used in 102(b), refers to the means by which a person

operates something, whether it be a car, a food processor, or

a computer. Thus a text describing how to operate something

-21- 21

would not extend copyright protection to the method of

operation itself; other people would be free to employ that

method and to describe it in their own words. Similarly, if

a new method of operation is used rather than described,

other people would still be free to employ or describe that

method.

We hold that the Lotus menu command hierarchy is an

uncopyrightable "method of operation." The Lotus menu

command hierarchy provides the means by which users control

and operate Lotus 1-2-3. If users wish to copy material, for

example, they use the "Copy" command. If users wish to print

material, they use the "Print" command. Users must use the

command terms to tell the computer what to do. Without the

menu command hierarchy, users would not be able to access and

control, or indeed make use of, Lotus 1-2-3's functional

capabilities.

The Lotus menu command hierarchy does not merely

explain and present Lotus 1-2-3's functional capabilities to

the user; it also serves as the method by which the program

is operated and controlled. The Lotus menu command hierarchy

is different from the Lotus long prompts, for the long

prompts are not necessary to the operation of the program;

users could operate Lotus 1-2-3 even if there were no long

-22- 22

prompts.9 The Lotus menu command hierarchy is also

different from the Lotus screen displays, for users need not

"use" any expressive aspects of the screen displays in order

to operate Lotus 1-2-3; because the way the screens look has

little bearing on how users control the program, the screen

displays are not part of Lotus 1-2-3's "method of

operation."10 The Lotus menu command hierarchy is also

different from the underlying computer code, because while

code is necessary for the program to work, its precise

formulation is not. In other words, to offer the same

capabilities as Lotus 1-2-3, Borland did not have to copy

Lotus's underlying code (and indeed it did not); to allow

users to operate its programs in substantially the same way,

however, Borland had to copy the Lotus menu command

hierarchy. Thus the Lotus 1-2-3 code is not a

uncopyrightable "method of operation."11

____________________

9. As the Lotus long prompts are not before us on appeal, we
take no position on their copyrightability, although we do
note that a strong argument could be made that the brief
explanations they provide "merge" with the underlying idea of
explaining such functions. See Morrissey v. Procter & Gamble ___ _________ ________________
Co., 379 F.2d 675, 678-79 (1st Cir. 1967) (when the possible ___
ways to express an idea are limited, the expression "merges"
with the idea and is therefore uncopyrightable; when merger
occurs, identical copying is permitted).

10. As they are not before us on appeal, we take no position
on whether the Lotus 1-2-3 screen displays constitute
original expression capable of being copyrighted.

11. Because the Lotus 1-2-3 code is not before us on appeal,
we take no position on whether it is copyrightable. We note,
however, that original computer codes generally are protected

-23- 23

The district court held that the Lotus menu command

hierarchy, with its specific choice and arrangement of

command terms, constituted an "expression" of the "idea" of

operating a computer program with commands arranged

hierarchically into menus and submenus. Borland II, 799 F. ___________

Supp. at 216. Under the district court's reasoning, Lotus's

decision to employ hierarchically arranged command terms to

operate its program could not foreclose its competitors from

also employing hierarchically arranged command terms to

operate their programs, but it did foreclose them from

employing the specific command terms and arrangement that

Lotus had used. In effect, the district court limited Lotus

1-2-3's "method of operation" to an abstraction.

Accepting the district court's finding that the

Lotus developers made some expressive choices in choosing and

arranging the Lotus command terms, we nonetheless hold that

that expression is not copyrightable because it is part of

Lotus 1-2-3's "method of operation." We do not think that

"methods of operation" are limited to abstractions; rather,

they are the means by which a user operates something. If

specific words are essential to operating something, then

they are part of a "method of operation" and, as such, are
____________________

by copyright. See, e.g., Altai, 982 F.2d at 702 ("It is now ___ ____ _____
well settled that the literal elements of computer programs,
i.e., their source and object codes, are the subject of
copyright protection.") (citing cases).

-24- 24

unprotectable. This is so whether they must be highlighted,

typed in, or even spoken, as computer programs no doubt will

soon be controlled by spoken words.

The fact that Lotus developers could have designed

the Lotus menu command hierarchy differently is immaterial to

the question of whether it is a "method of operation." In

other words, our initial inquiry is not whether the Lotus

menu command hierarchy incorporates any expression.12

Rather, our initial inquiry is whether the Lotus menu command

hierarchy is a "method of operation." Concluding, as we do,

that users operate Lotus 1-2-3 by using the Lotus menu

command hierarchy, and that the entire Lotus menu command

hierarchy is essential to operating Lotus 1-2-3, we do not

inquire further whether that method of operation could have

been designed differently. The "expressive" choices of what

to name the command terms and how to arrange them do not

magically change the uncopyrightable menu command hierarchy

into copyrightable subject matter.

Our holding that "methods of operation" are not

limited to mere abstractions is bolstered by Baker v. Selden. _____ ______

In Baker, the Supreme Court explained that _____

the teachings of science and the rules
and methods of useful art have their
final end in application and use; and
this application and use are what the

____________________

12. We think that the Altai test would contemplate this _____
being the initial inquiry.

-25- 25

public derive from the publication of a
book which teaches them. . . . The
description of the art in a book, though
entitled to the benefit of copyright,
lays no foundation for an exclusive claim
to the art itself. The object of the one
is explanation; the object of the other
is use. The former may be secured by
copyright. The latter can only be
secured, if it can be secured at all, by
letters-patent.

Baker v. Selden, 101 U.S. at 104-05. Lotus wrote its menu _____ ______

command hierarchy so that people could learn it and use it.

Accordingly, it falls squarely within the prohibition on

copyright protection established in Baker v. Selden and _____ ______

codified by Congress in 102(b).

In many ways, the Lotus menu command hierarchy is

like the buttons used to control, say, a video cassette

recorder ("VCR"). A VCR is a machine that enables one to

watch and record video tapes. Users operate VCRs by pressing

a series of buttons that are typically labelled "Record,

Play, Reverse, Fast Forward, Pause, Stop/Eject." That the

buttons are arranged and labeled does not make them a

"literary work," nor does it make them an "expression" of the

abstract "method of operating" a VCR via a set of labeled

buttons. Instead, the buttons are themselves the "method of

operating" the VCR.

When a Lotus 1-2-3 user chooses a command, either

by highlighting it on the screen or by typing its first

letter, he or she effectively pushes a button. Highlighting

-26- 26

the "Print" command on the screen, or typing the letter "P,"

is analogous to pressing a VCR button labeled "Play."

Just as one could not operate a buttonless VCR, it

would be impossible to operate Lotus 1-2-3 without employing

its menu command hierarchy. Thus the Lotus command terms are

not equivalent to the labels on the VCR's buttons, but are

instead equivalent to the buttons themselves. Unlike the

labels on a VCR's buttons, which merely make operating a VCR

easier by indicating the buttons' functions, the Lotus menu

commands are essential to operating Lotus 1-2-3. Without the<