Manufacturers Technologies v. CAMS

Citation: Manufacturers Technologies, Inc. v. CAMS, Inc., 706 F. Supp. 984 (D. Conn. 1989).

Factual Background
Plaintiff was the owner of a computer program that allowed a user to estimate the cost of machining a manufactured part. The program led the user through the estimation process using a sequence of computer screens asking for various information in a predefined, logical order. The defendant developed a competing cost estimation program.

District Court's Decision
The court wrestled with the question of which, if any, of the different screen displays for computer programs designed to aid in making cost estimates were subject to copyright protection. The court held a series of screen displays copyrightable, holding that:


 * The defendant has failed to rebut the presumption of copyright validity of this aspect of the screen displays. The flow of the plaintiff's [screen display]]s reflect plaintiff's creative manner of expressing how the process of cost-estimating should be accomplished.

It further noted that the flow and sequencing of these screens evidenced copyrightable selection and arrangement.

By contrast, the court held that certain aspects of the screen formatting style and method of navigating from one screen to another by use of certain keys were uncopyrightable because of the limited number of ways of expressing the underlying idea. Similarly, it held that four screens consisting of alphabetical displays of the departments were not subject to protection. The court reasoned that this "expression is not a proper subject of protection because it is necessarily incident to the idea of listing the departments, and there is no original authorship in this unadorned two-column alphabetical listing."

With regard to two other screens, the court also noted that functional considerations played a significant role in what data was given to the user and held that those screens were uncopyrightable. However, the court also held that a "job identification" screen was copyrightable under the "blank forms" analysis because it conveyed information in its manner of identifying a particular job.