Today, the Ninth Circuit ruled that yoga poses are not copyrightable under Section 102(b) of the Copyright Act because the Bikram sequence of 26 poses is an idea, process or system designed to improve health and copyright protects only the expression of this idea and not the idea of the sequence itself. The dispute arose after former Bikram Choudhury's students opened their own yoga studio and led clients through 26 poses just like the Bikram sequence. Choudhury sued for copyright violation under Section 102(b) for his 1979 book. In ruling against Choudhury, the Ninth Circuit reasoned that Section 102(b) expressly excludes protection of any idea, procedure, process, system, method of operation, concept, principle or discovery regardless of the form in which it is described, explained, illustrated or embodied; and because the sequence is an unprotected idea, it was also ineligible for protection as a 'compilation' or 'choreographic work.'
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