A recent 9th circuit Court of Appeals ruling determined that Bikram Yoga’s regimented exercise routine is not protected by copyright.
The determined that it was not copyrightable as a compilation or a choreographed work. The court held that the yoga poses encompassing Bikram is “an idea, process or system to which copyright protection may “[i]n no case” extend.” Essentially, the 9th circuit determined that the sequence of yoga poses fall within Section 102(b)’s exclusions from copyright protection.
The court makes the distinction between expression of ideas and the ideas themselves. The latter is not copyrightable while the former might be. The analogy utilized by the court here is that of a book describing a book-keeping system. While the book might be subject to copyright laws, the actual system for book-keeping would not.
The opinion negated arguments by Bikram that its sequence of poses, which were first published in a book, were transformative into copyrightable material. While the actual book is subject to copyright laws, the court determined that the actual poses and sequence are not.
The case is Bikram’s Yoga College of India L.P. and Bikram Choudhury v. Evolation Yoga LLC, et al.