Oracle Am. v. Google Inc.

Summarized by:

  • Court: Intellectual Property Archives
  • Area(s) of Law: Copyright
  • Date Filed: 05-09-2014
  • Case #: 2013-1021, 2013-1022
  • Judge(s)/Court Below: United States Court of Appeals for the Federal Circuit
  • LexisNexis Citation: 2014 U.S. App. LEXIS 8744
  • Full Text Opinion

When determining whether source code was eligible for copyright protection the court examined the legislative history of 17 U.S.C. §102(a).

Opinion (O’Malley): 37 packages of computer source code known as application programming interfaces ("APIs"), were created and licensed by Oracle as part of the Java programming language. Oracle alleged that Google infringed on its copyrights. A jury found that Google was infringing on Oracle’s copyrights in the Java API packages, but the district court judge would decide on the copyright ability of Oracle’s source code. The district court found that the elements of the 37 API packages, which included code, structure, organization and sequence, were not subject to copyright protection. Oracle appealed the ruling.

In order to analyze the copyrightability of computer programs, this Court cited the legislative history of the Copyright Act, 17 U.S.C. § 102(a), which states that protected literary works includes “computer programs” so long as they “incorporate authorship in the programmer’s expression of original ideas”. Additionally, the Court decided that literal elements of a computer program, such as the source code and object code, as well as the non-literal elements, can be subject to copyright protection. Non-literal elements include the graphical user interface, sequence, structure and organization.

Oracle’s source code in the 37 Java API packages is entitled to copyright protection. The Court AFFIRMED the district court’s judgment in part, REVERSED in part, and REMANDS the case.

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