Decisions in Brief

Recent Developments in IP Law

John C. Gatz

©2012. Published in Landslide, Vol. 5, No. 1, September/October 2012, by the American Bar Association. Reproduced with permission. All rights reserved. This information or any portion thereof may not be copied or disseminated in any form or by any means or stored in an electronic database or retrieval system without the express written consent of the American Bar Association or the copyright holder.



Dismissing Plaintiff’s Case Easy as Pi

Erickson v. Blake, ___F.3d___, 102 U.S.P.Q.2d 1466, (D. Or. 2012). Erickson is a composer who created an orchestral work entitled the “Pi Symphony,” inspired by the number pi. Erickson assigned a musical note to each digit between zero and nine, and then arranged the work based on the order of the digits of pi. Erickson registered a copyright in this work in 1992. In 2011, Blake posted a video on YouTube called “What Pi Sounds Like.” Blake also had assigned a note to each digit, and then arranged a work based on the digits of pi. Erickson sued Blake for copyright infringement, and Blake filed a motion to dismiss.


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