Mattel, Inc. v. Goldberger Doll Manufacturing Co.
365 F.3d 133 (2004)
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Rule of Law:
Copyright protection extends to an author's particularized expression of common or 'standard' features, so long as the expression was independently created and possesses a minimal degree of creativity. The fact that features are common does not automatically render them unprotectable 'ideas' that can be freely copied.
Facts:
- Mattel, Inc. is the creator of the Barbie doll and owns copyrights in its design.
- Mattel held registered copyrights for specific dolls, including 'Neptune's Daughter Barbie' (1992) and 'CEO Barbie' (1999).
- Radio City Entertainment operates the Radio City Music Hall in New York City.
- To celebrate the millennium, Radio City created and sold a doll named the 'Rockettes 2000' doll.
- The face of the 'Rockettes 2000' doll, particularly its eyes, nose, and mouth, appeared quite similar to the facial features of Mattel's Barbie dolls.
Procedural Posture:
- Mattel, Inc. sued Radio City Entertainment in the U.S. District Court for the Southern District of New York for copyright infringement.
- The district court granted summary judgment in favor of Radio City.
- The district court reasoned that features like 'pert, upturned noses; bow lips; [and] large, widely spaced eyes' were unprotectible standard doll features and excluded them from its 'substantial similarity' analysis.
- Mattel, as the appellant, appealed the grant of summary judgment to the U.S. Court of Appeals for the Second Circuit.
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Issue:
Does copyright protection extend to an author's particularized expression of common or 'standard' features, such as the eyes, nose, and mouth of a doll's face?
Opinions:
Majority - Leval, Circuit Judge
Yes, copyright protection extends to an author's particularized expression of common or 'standard' features. The district court erred in concluding that the central facial features of the Barbie dolls were unprotectable elements that could be freely copied. The standard for copyrightability requires only independent creation and a minimal degree of creativity, a threshold the Supreme Court has described as 'extremely low.' The proposition that standard or common features are not protected is inconsistent with copyright law. While the general 'idea' of a doll face with an upturned nose, bow lips, and wide eyes is in the public domain, Mattel's specific, particularized 'expression' of that idea is protected. There are innumerable ways to design such features, and Mattel's unique realization is protectable against copying, so long as it was independently created and possesses a spark of creativity.
Analysis:
This decision reaffirms the low threshold for originality in copyright law, clarifying that individual components of a work do not lose protection merely because they can be described as 'standard' or 'common' within a genre. It reinforces the critical distinction between an unprotectable idea and a protectable expression, preventing infringers from dissecting a copyrighted work into its constituent parts and claiming the right to copy any part deemed 'standard.' This ruling is significant for creators of characters, toys, and other artistic works, as it protects their specific creative choices even when working with conventional elements, thereby securing the commercial value of their particular design.
