Johnson v. Apple, Inc.

Plaintiff must show specific code or blueprint in order to sustain copyright infringement claim.

Opinion (Newman): Plaintiff Gregory Walker Johnson (“Johnson”) is an inventor in the telecommunications industry. Defendant Apple, Inc. (“Apple”) is a corporation that designs, develops, and sells consumer electronics and software. Johnson holds copyrights to “texts ‘describing a software application’” and purported that Apple infringed upon his copyrights by utilizing ideas articulated in the copyrighted texts in its’ consumer products. Apple moved to dismiss Johnson's complaint for failure to state a claim. A copyright infringement claims require that the Plaintiff establish: “ (1) ownership of a valid copyright; and (2) that ‘defendant copied protectable elements of the work.’” Copyright law protection extends to “original works of authorship fixed in any tangible medium of expression” and is only granted for the “expression of the idea — not the idea itself.” Protection does not encompass "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.” Johnson’s complaint alleged that Apple used Johnson’s copyrighted ideas in its’ products, but merely provided general descriptions of the copyrighted material within his complaint and failed to illustrate a “specific code or blueprint that Apple copied and developed.” The Court determined that the allegations within the complaint were for use of the ideas themselves and therefore rooted in patent law, not copyright law. As a result, Apple’s motion to dismiss was GRANTED.