Lotus v. Borland
| Lotus Development Corporation v. Borland International, Inc. | |
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| Argued January 8, 1996 Decided January 16, 1996 |
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| Full case name | Lotus Development Corporation v. Borland International, Inc. |
| Citations | 516 U.S. 233 (more)
49 F.3d 807 (1st Cir. 1995), aff'd, 516 U.S. 233, 116 S. Ct. 804; 133 L. Ed. 2d 610 (1996).
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| Prior history | Lotus claimed copyright infringement by Borland's Quattro Pro product. The district court ruled for Lotus, but this decision was reversed on appeal, finding that the allegedly infringing features of Quattro Pro were a "method of operation" not subject to copyright. Lotus petitioned the Supreme Court for a writ of certiorari, which was granted; however, because of a split opinion, the Supreme Court affirmed. |
| Holding | |
| The judgment of the United States Court of Appeals for the First Circuit is affirmed by an equally divided Court. | |
| Court membership | |
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| Case opinions | |
| Per curiam. | |
| Stevens took no part in the consideration or decision of the case. | |
| Laws applied | |
| 17 U.S.C. section 102(b) | |
Lotus Development Corporation v. Borland International, Inc., 516 U.S. 233 (1996), is a United States Supreme Court case that tested the extent of software copyright. The lower court had held that copyright does not extend to the user interface of a computer program, such as the text and layout of menus. Due to the recusal of one justice, the Supreme Court decided the case with an eight-member bench that split evenly, leaving the lower court's decision affirmed but setting no national precedent.
Borland released a spreadsheet product, Quattro Pro, that had a compatibility mode in which its menu imitated that of Lotus 1-2-3, a competing product. None of the source code or machine code that generated the menus was copied, but the names of the commands and the organization of those commands into a hierarchy were virtually identical.
Quattro Pro also contained a feature called "Key Reader", which allowed it to execute Lotus 1-2-3 keyboard macros. In order to support this feature, Quattro Pro's code contained a copy of Lotus's menu hierarchy in which each command was represented by its first letter instead of its entire name.
Borland CEO Philippe Kahn took the case to the software development community arguing that Lotus's position would stifle innovation and damage the future of software development. The vast majority of the software development community supported Borland's position.
Lotus filed suit in the United States District Court for the District of Massachusetts on July 2, 1990, claiming that the structure of the menus was copyrighted by Lotus. The district court ruled that Borland had infringed Lotus's copyright. The ruling was based in part on the fact that an alternative satisfactory menu structure could be designed. For example, the "Quit" command could be changed to "Exit."
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