Derived from ancient Hindu scriptures, the Indian practice andphilosophy of yoga date back thousands of years. It involves a combination of medication, breathing exercises, and physical poses (called asanas).

Bikram Choudhury was a lifelong student of a type of yoga known as Hatha. IN the early 1970s, he developed a method of practicing yoga, which he called Bikram. It consisted of a sequence of 26 Hatha yoga asanas, arranged in an order designed to work the muscles optimally (the Sequence). Choudhury’s other innovation was to teach the Sequence in a room heated to 105 degrees. Choudhury published and copyrighted a book that included descriptions, photographs, and drawings of the Sequence.

Many years later, Mark Drost and Zefea Samson, Choudhury’s former students, opened Evolation Yoga, a studio offering “hot yoga” classes. Evolation instructors taught the Sequence in a heated room in a manner and order identical to Bikram Yoga.

Choudhury sued Evolation Yoga for copyright infringement. He claimed that he deserved the exclusive right to perform the Sequence because he developed it over years of research and had copyrighted the book describing it. The district court granted summary judgment to Evolation, reasoning that the Sequence was an idea that could not be protected under copyright law.

Questions:

1. Was the Sequence copyrightable?

2. Did the court find copyright infringement?

3. What is the idea/expression dichotomy? 

4. Was the method Bikram created, promoted and memorialized in his book copyrightable?