Judge On Bikram’s Copyright Claim On Yoga Pose Sequence

Yoga poses don’t attract legal attention but now this is a significant ruling regarding the sequencing of yoga poses in Bikram Yoga in Bikram’s Yoga College vs. Evolation Yoga. Bikram Choudhury claimed that the competing yoga studio, Evolation Yoga, violated his copyright by teaching a sequence of 26 yoga postures and two breathing exercises that are similar to the sequence developed by Choudhury. It was ruled today that whereas the sequence in the book authored by Bikram Choudhary are copyrighted by Choudhary, that copyright cannot be invoked to stop others from using or teaching the sequence of poses.

So the key issue in the case was whether Choudhury owns a copyright to the sequence itself, which would allow him to prevent others from using it in their own yoga classes.

Choudhury filed a complaint in July 2011 in the U.S. District Court for the Central District of California alleging several claims against Evolation Yoga, including copyright infringement. Evolation Yoga denied the claims. A year later, the U.S. Copyright Office issued an advisory opinion stating that “a claim in a compilation of exercises or the selection and arrangement of yoga poses will be refused registration.”

In December 2012 the district court found that Choudhury’s sequence could not be copyrighted. Choudhury appealed the ruling..

Today, October 8, 2015, the Ninth Circuit Court of Appeals in California upheld the previous ruling by the federal district court that Bikram Choudhury’s sequence of 26 yoga poses is not entitled to copyright protection.This allows other teachers and studios to teach and practice the sequence without permission from Bikram Choudhary.

Writing for the three-judge panel, Judge Wardlaw wrote:

“We must decide whether a sequence of twenty-six yoga poses and two breathing exercises developed by Bikram Choudhury and described in his 1979 book, Bikram’s Beginning Yoga Class, is entitled to copyright protection. This question implicates a fundamental principle underlying constitutional and statutory copyright protection—the idea/expression dichotomy. Because copyright protection is limited to the expression of ideas, and does not extend to the ideas themselves, the Bikram Yoga Sequence is not a proper subject of copyright protection.”


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