The case involved UIRC, a company managing properties leased to the U.S. General Services Administration (GSA), seeking capital by pooling GSA properties and offering bonds. UIRC produced key documents for this process, including a private placement memorandum (PPM) and an indenture of trust, largely adapted from documents by the Idaho Housing and Finance Association, with the addition of some new language. The legal issue concerned the originality and copyrightability of UIRC’s documents, as copyright law requires works to be independently created with some degree of creativity to qualify for protection.
The district court ruled in favor of Blair, finding that UIRC’s documents lacked the necessary originality for copyright protection. The court noted that UIRC had extensively copied language from documents prepared by the Idaho Housing and Finance Association. Additionally, the court found that the new text added by UIRC consisted primarily of facts, fragmented phrases, or language dictated by functional considerations, which are not eligible for copyright protection.
UIRC chose to appeal, and the US Court of Appeals affirmed the district court’s decision to grant summary judgment in favor of Blair and to award attorneys’ fees. The ruling underscores the importance of originality in copyright law and serves as a reminder of the stringent requirements for copyright protection and the potential consequences of failing to meet these standards.
The case was appealed before Judge Michael B. Brennan, Judge Thomas L. Kirsch II, and Judge Joel M. Flaum, in the United States Court of Appeals For the Seventh Circuit, and assigned Case No. 23-1527 & 23-2566.