Sequence Of Exercises Is Not Proper Subject Matter For Copyright Protection

Bikram Choudhury, the originator of Bikram Yoga, succumbed to a summary judgment against a copyright infringement claim. Bikram Yoga is a version of yoga where a specific series of poses are performed in a hot room. Choudhury applied for and received a copyright registration for books describing the exercises to be performed.

Two trainees of Bikram Yoga began their own studio utilizing the same sequences and methods used by Choudhury. Previously, the copyright office had stated that, while the books and photographs depicting a compilation of exercises may be protected by copyright law, the “compilation authorship would not extend to the selection, coordination or arrangement of the exercises themselves that are depicted in the photographs or drawings.” The court agreed with the copyright office and further stated that the sequence of exercises is not proper subject matter for copyright protection because it is a collection of facts and ideas rather than an expression of a creative work.

105 U.S.P.Q.2d 1162 (S.D. Cal. 2012).