Bikram’s Yoga College v Evolation Yoga: Bikram Yoga’s Copyright Claim Wilts in the Heat

Bikram’s Yoga College v Evolation Yoga: Bikram Yoga’s Copyright Claim Wilts in the Heat
1 Bikram Yoga held not to be copyrightable

1 Bikram Yoga held not to be copyrightable

A recent decision passed by the US Federal Court could have implications for the burgeoning yoga community worldwide.

The Plaintiff was Bikram Choudhury, an Indian yoga teacher and the founder of Bikram Yoga. In 1979, Choudhury published his book – Bikram’s Beginning Yoga Class – which set out a sequence of 26 yoga poses and 2 breathing exercises (“the Sequence”), to be practiced in the course of 90 minutes to a series of instructions (“the Dialogue”) in a room heated to 105 degrees Fahrenheit. The book was registered with the US Copyright Office in 1979, and further registered as a “compilation of exercises” in 2002.

The Defendant was a yoga center founded by two of Choudhury’s former students, which taught a style of yoga with the same Sequence and Dialogue over 90 minutes in a room also heated to 105 degrees Fahrenheit.

Choudhury therefore brought a complaint against the Defendant for a claim of copyright infringement of the Sequence and Dialogue.

The Federal Court however, was quick to come to the conclusion that neither the Sequence nor the Dialogue could be protected by copyright. In its opinion, Judge Wardlaw elaborated on a crucial tenet that copyright only offers protection for the expression of an idea, and not the idea itself.

Section 102(a) of the US Copyright Act further expressly excludes protection for “any idea, procedure, process [or] system” (“Section 102(a)”). Given that the Sequence and the Dialogue were designed as a system to yield physical benefits and a sense of well-being, they therefore could not be the subject of copyright protection. Any protection for the Sequence and Dialogue, if at all, should have been obtained under the patents system in the US.

The court was also mindful of the overarching purpose of copyright law – i.e. the need to preserve the balance between competition and protection. The court observed that the Sequence and Dialogue could not be copyrighted, as “consumers would have very little reason to buy Choudhury’s book if Choudhury held a monopoly on the practice of the very activity he sought to popularize”.

For the above reasons, Choudhury’s claim for copyright infringement failed. The future of Bikram Yoga (and other yoga methods) as a business in the US is therefore now in question. However, it should be noted that Singapore’s Copyright Act does not contain an equivalent of Section 102(a) – how a similar case would pan out in Singapore therefore remains to be seen.