Bikram’s Yoga Coll. of India, L.P. v. Evolation Yoga, LLC, 2012 WL 6548505 (C.D. Cal. Dec. 14, 2012)– Yogi Bikram Choudhury developed the Bikram style of hot yoga and used brand name “Bikram” since 1971. Choudhury has multiple copyright registrations for his yoga instructional videos and materials. Choudhury sued Evolation Yoga, LLC alleging copyright infringement of the Bikram sequence.
In Bikram’s case, the Central District of California held:
1) Only Choudhury’s expression of the facts and ideas contained within, and not the facts and ideas themselves are protected by copyright as literary and audiovisual works.
2) A compilation of exercises or yoga poses itself does not fall into any of the copyrightable categories under 17 U.S.C. §102(a) and is not copyrightable under s. 102(b) because it is a system or procedure.
Law in Style. 