No Copyright Protection for Hot Yoga Sequence

People engage in yoga training to achieve anything ranging from spiritual fulfillment to overall physical fitness.  Bikram Choudhury developed a sequence of twenty-six yoga poses and two breathing exercises (the Sequence), described in his book, Bikram’s Beginning Yoga Class.  Choudhury’s Bikram Yoga studios offer instruction in performing the Sequence over a ninety minute session in a room heated to 105 degrees Fahrenheit.  Choudhury actively markets the health and fitness benefits the Sequence provides.  Mark Drost and Zefea Samson completed the Bikram Yoga Teacher Training course and later, in 2009, opened Evolution Yoga.  Evolution Yoga teaches a 26 posture and 2 breathing exercise routine performed in 90 minutes in a 105 degree Fahrenheit room. 

Choudhury and Bikram’s Yoga College of India, L.P. sued Evolution Yoga for infringing Bikram’s copyright in the Sequence.  The district court granted Evolution’s motion for summary judgement on the copyright infringement issue, ruling that the Sequence is a collection of facts and ideas that is not entitled to copyright protection.  The Ninth Circuit affirmed the district court’s ruling.

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