BAKER V. SELDEN 101 U.S. 99 (1879)
FACTS
Charles Selden (P), obtained a copyright of the book “Selden’s Condensed Ledger or Book-Keeping Simplified” in 1859 and this book explained a unique and improved system of book-keeping with a distinct arrangement of columns and headings. In 1867, Baker, the defendant, produced another book using a similar system but the arrangement of columns and their headings were different.
Idea-Expression Dichotomy: A copyright can be obtained only over a particular expression of an idea, it does not protect the idea that underlies that expression and this is what limits copyrights and differentiates it from patents. An idea/art/method can be patented whereas the expression of an idea/art/method can be copyrighted.
PROCEDURAL HISTORY
A suit was filed against the D for infringing copyrights of Selden’s book as Baker had used a system that resembled the one used in Selden’s work and the lower court ruled in favor of P. The D then appealed to the US Supreme Court.
ISSUES
1) Did the D infringe the copyright?
2) Did Selden have an exclusive right to the use of the system explained in his book?
HELD
1) No, the D did not infringe copyright of the book “Selden’s Condensed Ledger or Book-Keeping Simplified”.
2) No, Selden did not have an exclusive right to the use of the system explained in his book.
The court reasoned that an author can explain the truths of a science or the methods of an art through his book and can obtain a copyright for his work but this copyright is limited to the expression of the method or system and does not extend to the idea or the system itself. If the author wants to protect the system/idea he will have to be granted a patent for his method/idea and protecting an idea under the copyright law would amount to fraud on the public.
Copyright protects the book as a whole and the expression of an idea through that book. The very object of publishing a book is to impart some knowledge to the public and if people were made liable of infringement each time they used the idea described in the book, it would defeat the purpose. Copyright is mainly concerned with publishing and selling rights and does not give the author exclusive rights over an idea alone.
In this case, Baker was not infringing the copyrights of Selden’s book as he borrowed the idea from Selden’s book but expressed it in a different manner by ensuring that the columns and headings to those columns were different.