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Civil Procedure Keyed to Counsellor, 3rd Ed.
Hays v. Sony Corp. of America
Citation:
847 F.2d 412 (1988)Facts
In 1982 or 1983, Stephanie Hays and Gail MacDonald, business teachers at a public high school in Des Plaines, Illinois, prepared a manual for their students on how to operate the school’s DEC word processors. In 1984, after the school district purchased word processors from Sony, it gave the plaintiffs’ manual to Sony and asked the company to modify it for use with Sony’s word processors. Sony created a manual very similar to the plaintiffs’ work, with many verbatim copies of portions of the original. Sony did not charge for preparing the manual and there was no evidence Sony sold or distributed it elsewhere. In February 1985, the plaintiffs registered their manual with the Copyright Office and filed suit in July, alleging both common law copyright and statutory copyright violations. The district court dismissed the action, finding the plaintiffs failed to state a claim, and later awarded sanctions against their attorney for pursuing frivolous claims.
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