Copyright Infringement

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7^th Circuit Court of Appeals

Case Name: UIRC-GSA Holdings, LLC v. William Blair & Company, L.L.C.

Case No.: 23-1527

Officials: Flaum, Brennan, and Kirsch, Circuit Judges.

Focus: Copyright Infringement

UIRC, a company specializing in acquiring and managing properties for the U.S. government, initiated a lawsuit against Blair, a financial services company, alleging copyright infringement. They claimed that Blair copied original content from their bond offering documents during a similar offering with a third party. The District Court granted Blair’s motion for summary judgment, asserting that UIRC’s documents lacked the necessary originality for valid copyrights. Additionally, the court awarded attorney’s fees to Blair under the Copyright Act.

The Seventh Circuit concurred with the District Court’s finding that a significant portion of the language in UIRC’s documents had been copied from materials created by another entity, the Idaho Housing and Finance Association. The court also determined that the language UIRC did compose lacked the creative expression required for copyright protection, being comprised of facts, fragmented phrases, or language dictated solely by functional considerations. Consequently, UIRC did not possess a valid copyright in the bond documents it alleged Blair had copied.

The Court of Appeals also affirmed the District Court’s decision to grant attorney’s fees to Blair. In reaching this conclusion, the District Court considered various factors, including the meritless nature of the lawsuit, the motivation of the losing party, the objective unreasonableness of the claims presented, and the need to address compensation and deterrence concerns.

Affirmed.

Decided 01/12/24

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