West Publishing Company, Appellee v. Mead Data Central, Inc., Appellant (8th Cir. 1986)

Summary

The court affirmed a preliminary injunction barring Mead Data Central from adding West's internal page citations to the LEXIS database. It held, on the preliminary-injunction record, that West's arrangement of reported cases, including its internal pagination, was sufficiently original for copyright protection and that the proposed star-pagination feature would appropriate that protected arrangement and likely infringe it. The court also held that the district court properly balanced the preliminary-injunction factors and did not abuse its discretion. Oliver, Senior District Judge, concurring in part and dissenting in part, would have reversed the injunction because the interlocutory record did not support definitive conclusions about originality or infringement.

Holding

Copyrightability of West's arrangement and pagination. On the preliminary record, West's arrangement of cases in its National Reporter System, of which internal page citations were an important part, was an original work of authorship entitled to copyright protection. The protection was for the arrangement and compilation as a whole, not for the Arabic numbers themselves.

Infringement by star pagination. Mead Data's proposed star-pagination feature would likely infringe West's copyright because it would reproduce West's page breaks and internal page numbers in a manner that communicated the precise location of text within West's copyrighted arrangement and could substitute for access to West's volumes.

Propriety of the preliminary injunction. The district court did not abuse its discretion in granting the preliminary injunction because the probability of West's success, the presumption and evidence of irreparable harm, the balance of harms, and the public interest favored injunctive relief.

West Publishing Company, Appellee v. Mead Data Central, Inc., Appellant

Summary

Holding

Cited authorities

Cited by