Feist Publications, Inc. v. Rural Telephone Service Co., Inc.

Summary

The Supreme Court held that facts are not copyrightable, while factual compilations may receive limited copyright protection for original selection or arrangement. Applying the originality requirement, the Court concluded that Rural Telephone Service’s white-pages directory lacked the requisite originality because its listings were arranged in an obvious, alphabetical manner. Feist Publications therefore did not infringe Rural’s copyright by copying names, towns, and telephone numbers.

Holdings

1. Facts, including names, towns, and telephone numbers, are not copyrightable because they are discoveries rather than original works of authorship.
2. A factual compilation is copyrightable only if its selection, coordination, or arrangement is original and contains at least a minimal degree of creativity.
3. Rural's white pages directory was not sufficiently original because it merely listed basic subscriber information alphabetically, an arrangement that lacked the minimal creative spark required for copyright protection.
4. Feist's copying of Rural's names, towns, and telephone numbers did not constitute copyright infringement because those copied elements were uncopyrightable facts and Rural's arrangement lacked originality.

Questions Presented

1. Whether facts such as subscribers' names, towns, and telephone numbers are protected by copyright.
2. Whether Rural's selection and alphabetical arrangement of those factual listings were sufficiently original to receive copyright protection.
3. Whether Feist's copying of 1,309 listings constituted copyright infringement.

Disposition

reversed