Gaines v. District of Columbia

Under the idea/expression dichotomy of copyright protection, copyright assures authors the right to their original expression but does not give anyone exclusive rights to ideas.

Opinion (Rothstein): Plaintiff holds a registered copyright for a manual detailing methods for inputting handwritten numbers into betting slips. Plaintiff, from 1998 to 2012, corresponded and met with employees of the District of Columbia Lottery Board with regards to implementing his copyrighted system of inputting numbers and printing advertisements on the lottery betting slips. After this communication but with no subsequent deal between the parties, the District of Columbia Lottery Board printed commemorative Mega Millions lottery tickets. Plaintiff believed these commemorative lottery tickets to be a derivative work involving his copyrighted ideas. Plaintiff filed a complaint alleging copyright infringement and a motion for summary judgment. The court explained that, under the Copyright Act, an idea cannot be the subject of copyright protection, and since Plaintiff's idea to place a commemorative image on the back of lottery tickets is not included in the copyrighted components of his manual, he is not entitled to judgment against the DC Lottery Board for copyright infringement. The court also found no substantial similarity between Plaintiff's copyrighted work and the District of Columbia’s lottery tickets. As a result of these findings, the Court DENIED Plaintiff's motion for summary judgment and GRANTED the District’s motion to dismiss.