A federal court in Connecticut has issued an important decision in the area of copyright protection of computer screen displays. The plaintiff in the case, Manufacturers Technologies, Inc. (“MTI”), owns a program that enables users to estimate the cost of machining a manufactured part. The defendants, former sales representatives of MTI, formed a company called CAMS, Inc., which developed a look-alike “budget” version of MTI’s product, which CAMS “budget” version of MTI’s product, which CAMS licensed for as little as 10% of MTI’s price. The case did not involve allegations that source code had been copied.
Both MTI and CAMS used character-based (as opposed to graphical) screen displays that prompted the user to enter various aspects of cost-related information, which were then mathematically manipulated by the software. MTI claimed that the “flow” (i.e., the structure, sequence and organization) of the screens in the CAMS program, as well as individual screens themselves, infringed MTI’s copyrights.
The court identified the screen flow as the “external” aspect of the displays. It found that the flow of the screens reflected MTI’s “creative manner of expressing how the process of cost- estimating should be accomplished.” Because the screen flow was not driven solely by functional considerations, the court found this external aspect of the displays to be protectible by copyright, and further found that CAMS’ screen flow was so similar as to be infringing. The court declined to extend copyright protection to formatting styles used in the screens, and the techniques the program used to navigate within a given screen.
The court referred to the features of individual screens as the “internal” aspect of the displays. MTI had claimed infringement of a number of screens, independent of their role in the program’s flow. The court declined to extend protection in several instances, where the screens made use of commonly used columnar formats; however, it did find protectible a screen listing certain criteria that are entered by the user and manipulated by the program.
TLB Comment: The MTI case dramatically underscores the broad protection that the federal courts are willing to provide to computer screen displays. As recently as two years ago, few observers would have expected that relatively simple character-based screen displays such as those at issue in MTI would become the subject of successful copyright infringement actions. The MTI court’s express recognition of copyright protection for character-based screen flows bodes ill for Paperback Software and Mosaic Software, both of which are defendants in copyright suits brought by Lotus, which claims that these companies have infringed the structure, sequence, and organization of the menus used in 1-2-3.
Postscript: This case may have represented the high water mark in the liberal extension of U.S. copyright law to non-graphical software user interfaces. In the wake of decisions of the 1990s discussed elsewhere in this section of our site, it is questionable whether the case has any serious continuing viability.