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The Tabberone™ Archives These articles concern what we consider major trademark and copyright issues. They are usually reproduced with the original source referenced. Bear in mind, these articles are copyrighted and commercial use without permission of the authors may be considered infringement. The intended use here is educational, commentary and non-commercial. The reason they are reproduced in the Tabberone™ Archives, as opposed to just providing a link, is because links disappear and pages are removed. That presents a messy confirmation process that is annoying to the browser (you) but also presents a credibility issue. We do not claim any rights in these pieces. Do not regard the absence of a copyright statement or © to mean the article is not copyrighted. Some sites do not have a copyright statement. When an article or a comment is posted on the internet by the copyright owner, the owner is seeking a world-wide, 24/7 audience; sometimes for a limited amount of time, sometimes indefinitely. In essence, an internet posting intentionally relinquishes one's copyright for exclusivity because the owner has posted it on the internet to been seen by everyone, everywhere. The Tabberone™ Archives non-commercial duplication of the posting is simply a continuance of the original wishes of the copyright owner. We post these articles for reference, for commentary and for confirmarion of our position. |
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Source: http://www.bc.edu/bc_org/avp/law/st_org/iptf/articles/content/1997121201.html Article has been reformatted for easier reading. |
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1997 B.C. Intell. Prop. & Tech. F. 121201
A Design for the Copyright of Fashion
I. Introduction Fashion apparel is a multi-billion dollar industry that has no national boundaries. Designers[1], retailers and consumers follow the game of international fashion. Within the last decade, consumer knowledge of specific designers has increased dramatically. Magazines and newspapers now cover the fashion industry as part of their national news coverage, focusing on the ever-changing world of creative designer expressions.[2] The general public has a ready command of the names and faces of fashion models and the designers for which they model. Countless television shows and feature films[3] exploit the fashion industry world. Consumers can now recognize the distinct style of their favorite designers: Chanel, jersey-knit double-breasted suits in contrast colors with trademarked brass buttons, and quilted leather accessories; Gianni Versace, colorful handprinted silks with reproduced 17th and 18th century illustrations; Issey Miyake, sparse deconstructed gender neutral garments in natural fabrics or highly unnatural polymers, which redefine both form and movement.[4] In 1977, former Register of Copyrights Barbara Ringer stated that the issue of design protection is "one of the most significant and pressing items of unfinished business" of copyright revision.[5] This issue remains unaddressed today, even though the need for revision is even more significant, because garment designs lie along the fringe area of creative expressions that exhibit the same qualities as protected matter. This paper suggests that the traditional reasoning which denied certain articles copyright protection is no longer reasonable, and that protection should now be extended to garment designs. Further, this paper proposes solutions to the problems of implementing copyright for fashion and what effect copyright will have on the garment industry and consumers. II. History of Non-Protection of Fashion A. Reasoning Behind Non-Protection of Garment Design Copyright protection is denied to garment designs due to the misconception that garment designs are solely useful articles without any copyrightable elements. Useful articles are granted limited protection under the Copyright Act, provided there are elements of the pictorial, graphic, or sculptural work that may be identified separately and can exist independently of the utilitarian aspects of the article.[6] Since 1914, several bills[7] have been handed down to Congress advocating the protection of the designs of useful articles through copyright.[8] Such protection of garment designs has always been opposed, however, for to do otherwise, would arguably grant protection to a purely utilitarian article and pave the way for a monopolies in the apparel market.
Although many garment designs maintain an underlying utilitarian function,
many designers have crossed the traditional boundaries of wearable apparel into
wearable art. The creations of haute couture[9], for example, are not meant to be worn as clothing, but
rather as an embodiment of all the design statements made in the ready-to-wear
line, albeit toned down.[10] Moreover,
subsequent copyright cases distinguish between a utilitarian object and its
artistic appearance, so that an object's artistic qualities may entitle it to
copyright protection despite its utilitarian function.[11] Under the reasoning followed in Barnhart v.
Economy Cover, aesthetic features of a useful article may be
protected when they are not in any way required or necessary for the
performance of the utilitarian function.[12]
Thus, one might reasonably conclude that most, if not all, garment designs
could be treated as protectable, for their aesthetic elements go far beyond the
simple function of clothing.[13] Considering
the nature of fashion as exhibited today, the policy of prohibiting copyright
in garment design is outdated and no longer serves the purpose of preserving
useful ideas for the general public.
B. Attempts at Design Protection Through Other Areas of Law A designer's unpublished work, in this case, not yet put on the market or otherwise displayed to the public, may be protected under common law.[20] This is, however, hollow protection for designers whose value in their creations depend on public awareness and buying power. Thus, due to the denial of copyright protection for garment designs, designers have looked to other areas of federal and state legislation, such as design patents, trademark and unfair competition, and trade restrictions to obtain protection for their creations.[21] Just as with copyright, however, these attempts have proved unavailable or ineffective.[22] 1. Design Patents Under the design patent statutes, protection is granted to a "new, original and ornamental design for an article of manufacture."[23] A design patent will protect the configuration or ornamental elements of a product which gives a distinctive appearance.[24] In order to be eligible for protection the article's design must be novel, non-obvious, ornamental and meet the test of invention.[25] Garment designs have consistently been held to have failed these requirements.[26] Even if the design patent statutes were modified to allow inclusion of garment designs, the protection obtained would be useless. The patent process is lengthy, most notably due to the prior art search,[27] which could be quite unwieldy with regard to fashion elements. Design patents are most effective when the element sought to be protected is used repeatedly and has a shelf life of many years. Fashion, to the contrary, is notoriously ephemeral and transient; what is "in" this season, is passè the next. Thus, designers could only seek to prove retroactive infringement, after much of the revenue and importance of the design has passed.[28] 2. Trademarks and Unfair Competition Trademark law serves to protect the "mark-good" combination.[29] In order to receive protection, the trademark must be employed with a certain product, such that the public recognizes the mark and associates the elements and qualities of the product with the good.[30] An example of a trademark is the ubiquitous Nike `swoosh.' The general public recognizes this graphic element as belonging to a genuine Nike product, and thus expects a certain caliber of product to be attached to the mark. While trademark law will protect that designer from unauthorized use of the registered mark, in this case a designer's "label", it will not protect the actual garment design. Under this reasoning, a manufacturer could make an exact reproduction of a garment design, without suffering any repercussions under trademark law. Moreover, the same manufacturer could use the designer's name and marks to promote his copy as an exact reproduction of the designer's work,[31] thus bringing the "truth in advertising" theory to its most logical conclusion. In connection with a claim of trademark infringement, many designers have attempted to protect their marks and creations by bringing claims of unfair competition. In this way, a designer must show that the sale of a copy is likely to confuse the public, because the public has acquired a "secondary meaning"[32] for the mark. Although some designers who repeatedly utilize their trademarks with their garments and fabric patterns, such as Chanel, Mossimo, Gucci, and Louis Vuitton, may be successful in pursuing such a claim, the majority of designers will be defeated by the transient and seasonal nature of the industry.[33] This is exemplified by the number of cases where unfair competition has been denied to fashion designers.[34]
3. Trade Restrictions
It seems, therefore, that copyright is the most appropriate method of protecting the creative expressions of fashion designers. No other method is effective to protect the property interest and value of the garment design or the inherent and complicated nature of the industry. Courts, in denying the protection of copyright and other legal remedies, have stated that copyright protection would still provide a readily workable solution to the problems of design theft, without impinging the free market of ideas.[41] C. Fabric Pattern Protection Currently the only available copyright protection for a designer's fashion rests with the protection of the actual fabric design. An author's sole right to the first printing and publishing of his work was adopted by the U.S. Constitution from the English common law system and codified as the Copyright Act of 1790.[42] The Act authorized Congress "to promote the progress of science and useful arts, by securing, for a limited time to authors and inventors, the exclusive right to their respective writings and discoveries."[43] The word "writings" has been broadly construed by the courts to include fabric designs, but distinguishes the actual "dress design" as an unprotected useful article.[44] Fabric designs are deemed to be consistent with the similarly copyrightable expressions of paintings and other pictorial or graphic materials.[45] While the copyright of a fabric design does afford a fashion designer some protection, it only extends to the actual fabric and not the garment that is created from it. Many designers do not create their own fabric, instead they buy cloth from manufacturers without taking any assignment of its copyright. As a result, the value of any recovery for infringement of a copyrighted fabric pattern would be limited to the value of the fabric as cloth, not as the garment or product created with the fabric. Assuming the designer actually creates his own patterns, protection for fabric is only offered if the designer uses fabric with intricate and complicated patterns and designs. Still, the copyright protection is extremely narrow, for it is judged under the "ordinary viewer" test. Copyright infringement may be inferred when proved that a defendant had access to the copyrighted work and substantial similarities to the protected material exist.[46] Even if a plaintiff can show access, there is no infringement when the similarities between the works are insufficient to prove copying.[47] The test then asks whether "the ordinary observer, unless he set out to detect the disparities, would be disposed to overlook them, and regard their aesthetic appeal as the same."[48] It is not inconceivable then, under this standard, that most fabric designs would fail to be protected unless there is evidence of egregious copying by the defendant.[49] Nonetheless, fabric designs are routinely copied, or euphemistically, "used for inspiration" by other fabric designers in creating other patterns.[50] III. Reasons to Protect Garment Designs Through Copyright On May 2, 1991, the Copyright Office (Office) issued a Notice of Inquiry to the public requesting comments on the Office's practices regarding the registerability of three-dimensional garment or costume designs.[51] The Office wished to maintain settled copyright principles concerning conceptual separability and the useful article doctrine. It stated that marketability and aesthetic quality would continue to be excluded from consideration.[52] The Office solicited commentary on four main policy questions, three of which were of great importance to the fashion industry, as they could have resulted in a change of policy for certain garment designs.[53] The Office, however, continued to uphold the traditional, restrictive interpretations of the Copyright Act and its pictorial and graphic provisions.[54] These provisions would not allow garment designs copyright protection even if they contained ornamental features or were intended to be used as historical or period dress.[55] The Office, having received many public comments arguing for a broader availability of copyright protection to include garment designs, advised those interested parties to seek Congressional revision of the Copyright Act.[56] Until such a revision, the Office would continue to draw the line "between works of imagination (masks and some costumes) and works of utility (garments)".[57]
A. Monopoly in Clothing Does Not Exist
B. Architectural and Technical Drawings Protection Inequity The interpretation of the Copyright Act and its policies have created many inequities with respect to the useful article doctrine. Perhaps none more so than the allowance of copyright protection for technical drawings, architectural renderings, and the actual products of the architecture. Under the current Act, a drafter of architectural or technical drawings may copyright his work as pictorial or graphic expression.[62] While giving some credence to the argument that architectural and technical renderings contain aesthetic elements, these renderings are used exclusively for utilitarian purposes. In comparison to architectural renderings, it is difficult to comprehend why a garment design fails to achieve protection.[63] C. Comporting with International Copyright Standards On March 1, 1989[64], the United States officially entered the Berne Convention for the Protection of Literary and Artistic Works (Berne Convention), helped to pass the Berne Convention Implementation Act of 1988 (BCIA)[65], and subsequently ratified the treaty.[66] In adopting the Berne Convention provisions, the United States only complied with its minimum requirements.[67] The rights and responsibilities relating to copyright matters are now to be resolved under domestic law, not under the provisions of the international treaty.[68] This has led to some conflicts regarding the protection afforded to copyright holders.[69] While other conflicts have been resolved in favor of the authors' rights[70], the protection of fashion designers remains a contradiction. Under international rules, the creative works of fashion designers are protected by copyright, albeit for a limited term.[71] The works which are protected against pirating in Europe receive no such protection in the U.S.[72] Thus, each time a designer shows new work, it may be copied exactly and reproduced for sale in the U.S. In addition, the design copier may use the original designer's name in his advertisement.[73] The U.S. constantly alleges that other countries are not doing enough to protect the copyrighted works of American authors,[74] yet fails to extend its own copyright protection for certain works, most notably the creations of fashion designers. This inequity undermines the fashion design markets in the U.S.[75] Many designers are also powerless to combat the effect of the resulting grey goods market, although international laws attempt to prohibit the importation of such products.
D. Garment Designs Are Not Solely Useful Articles
It has been well recognized that the "chief value of a `quality' dress lies, not so much in the quality of the material, as in the smartness and originality of the design."[80] While an obvious element of utility is usually inherent in garment designs, the primary purpose and value to the designer lie in their appearance. Because copyright law aims to protect and encourage creative works of art, allowing protection for garment designs poses no contradiction to the underlying policy.[81] Garment designers have attempted, to no avail, to rely on other areas to protect their intellectual property rights. In fact, the courts which have denied the use of other remedies have stated that the most applicable and most reasonable solution to the quandary of garment designs is the extension of copyright protection. Unfortunately the legislature has been wary of such an extension. The 1991 call for comments by the Copyright Office, however, shows that the federal government is not unamenable. Rather, it appears to be looking for an argument that would not only withstand a useful article debate, but also a more politicized debate that copyright protection is being extended too far.[82] IV. Implementation of Fashion Design Copyright Beyond the mere establishment of fashion design copyright, there are additional problems regarding the efficient implementation of new protection. In addition to offering solutions to practical concerns, this paper suggests formulating a doctrine to determine which elements of a garment design may be protected by copyright. As with all useful articles, the grant of copyright is conditioned on the existence of separate aesthetic elements. Although there is an argument against incorporating only one method of inquiry into the conceptual separability test, this paper seeks to only use the test that would better represent the garment industry. A. Conceptual Separability of Fashion's Artistic Elements From the Functionality of Clothing: The Need for Revision
Under current copyright law, useful, functional articles are denied protection
based in part on a belief that when creating a particular manifestation of a
useful article, an artist will receive comprehensive protection that exceeds
the original expression of its particular aesthetic qualities. Courts do not
want to foreclose competitors from using the same design, thus depriving
consumers of the useful article's benefits.
In the language of the Copyright Act of 1976, a useful article is "an article having an intrinsic utilitarian function that is not merely used to portray the appearance of the article or to convey information."[83] A useful article need not be a complicated device that can only be expressed within a limited number of designs.[84] Additionally, "an article that is normally a part of a useful article is considered a useful article."[85] Such an article enjoys copyright protection "only to the extent that [its] design incorporates pictorial, graphic, or sculptural features that can be identified from, and are capable of existing separately from the utilitarian aspects of the article."[86] Determining the separability of the useful article's utilitarian function from its artistic features is the paramount concern of a court when considering the appropriateness of copyright protection.[87] Ordinarily, the distinction between protectable works of authorship and useful articles works perfectly well, barring copyright in purely technological advances, processes and functional works.[88] A dilemma arises, however, when the attraction of a useful article does not necessarily arise from the article's "intrinsic utilitarian function".[89] Rather, a peculiar attribute or design can appeal to a consumer's aesthetic notions, regardless of the utilitarian application or function of the article.[90] This is the realm into which fashion design falls; to the consumer, the item's appearance is of paramount importance, whereas the utilitarian aspect is incidental.[91] Separating the purely aesthetic elements from the intrinsically functional elements of the useful article generates problems for courts. Currently, there is no clear guideline for such determination because numerous sources of authority espouse different methods for determining copyright protection.[92] Such confusion has resulted in courts erring on the side of underprotection under a strict formalism, even though the useful article contains a particular visual appeal.[93] 1. The Majority Approach to Separability: Physical and Conceptual
For a useful article to be copyrightable, the court must first consider if the
artistic element of the article is separable from its utilitarian
application.[94] When aesthetics can
physically separate the artistic elements from the article without also
removing its intrinsic utilitarian function, the analysis is relatively
simple.[95] If the aesthetic element may not
be so removed, the Registry of Copyright and the courts look to the possibility
of "conceptually" separating the artistic element from the useful article.[96] Unlike physical separability, conceptual
separability recognizes that a useful article can contain both aesthetic and
functional elements and still merit copyright protection. As critics point
out, however, current interpretations of conceptual separability could leave a
court determining the nature of the aesthetic elements and ultimately deciding
upon the level of artistic merit.[97]
2. Conceptual Separability Under the Creative Process Model A more appropriate focal point for courts determining the protection of useful articles is the creative process, rather than the useful article itself.[99] Thus, the motivations of the artist who creates the article dictate whether the ultimate function of the article is aesthetic or utilitarian.[100] The mere fact that the article contains both elements does not immediately discount the availability of protection, but rather furthers the spirit behind copyright protection for objects that add to the cultural, creative and artistic wealth of the society.[101] Properly implemented, this interpretation will provide expanded protection for otherwise unprotected useful articles. The creative process model, however, may prove completely unworkable in the practical courtroom setting, as it ultimately depends on whether or not a designer can prove and record the pure artistic creative process behind the useful article.[102] The court may find itself deciding the artistic merit of an object, contrary to the long held principal of avoiding such decisions.[103] Further, this model assumes that there will be a recognizable difference in the creative processes, such that the artistic element may be discerned from the utilitarian and that a reasonable trier of fact would be able to comprehend the difference between the creative process of a fashion designer and that of a mere clothing manufacturer. [104] 3. The Temporal Displacement Test Judge Newman, dissenting in Barnhart, delineated a different approach to conceptual separability for useful articles.[105] According to Newman, "for the design features to be conceptually separable from the utilitarian aspects of the useful article that embodies the design, the article must stimulate in the mind of the beholder a concept that is separate from the concept evoked by its utilitarian function."[106] This approach has become known as the "temporal displacement" test.[107] It recognizes that the decision regarding whether an item is able to exist as art, despite its utility, is ultimately in the eyes of the beholder.[108] Because every useful article could be held as "art" by at least one person, the boundaries of what is protectable have been eradicated. Further, the creative motivations of the artist or designer are meaningless.[109] 4. The Polakovic Approach to Conceptual Separability According to Professor Polakovic, the proper standard for determining which useful articles are to be protected rests in the combination of the creative process approach and temporal displacement approach.[110] His analysis would take into account the creative process of both the designer and the artist, while taking a more accommodating view of the artistic contributions of the designer.[111] Designs that achieve their aesthetic appeal solely from their utilitarian function would not be protected. [112] Thus, the designer would first be treated as an artist, one whose medium deserves protection when it does not amount to an application of a utilitarian function.[113] 5. Application of the Polakovic Model
Under Polakovic's approach, the fashion designer would receive the same
treatment as any other artist. Although not all the designs created would be
protected under this model, the fashion designer would have a better chance
proving that his creations are art and engendered with creative process, even
though he has expressed himself through the medium of fabric. The main
obstacle for the designer will be the court's decision regarding the underlying
idea behind the useful article and whether the elements of the useful article
are viewed as either ideas or expressions of that idea. In other words, the
court will determine the level of abstraction.
In Whimsicality Inc. v. Rubie's Costumes Co., the court determined that a costume serves the utilitarian function of allowing the wearer to masquerade.[114] Thus, the motivation of the artist was to create a costume, and the actual production of such an article, under this strict interpretation, will automatically be refused copyright.[115] If, however, a court applies a broader and more abstract analysis, as it did in National Theme Products, Inc. v. Jerry B. Beck Inc., a costume, although a useful article with which one masquerades, is deemed to be mere clothing.[116] As a result, the costume would be amenable to copyright protection, for the intentions of the artist were to create a particular, adorned article of clothing that does not constitute an unprotected, useful article under the Copyright Act.[117] Practically, the trier of fact in an action for infringement would need to be acquainted with both the complexities of a particular application and the difficulties of resolving these complexities when creating a single design and attempting to give the article its aesthetic appeal.[118] Even assuming the legislature allowed copyright protection for these expressions, the current approach of the courts is too comprehensive and would all but eliminate the copyrightability of a fashion design. The proper approach is to determine: 1) why the useful article is appealing; and 2) whether the source of its appeal is an imperative component of its function.[119] As a result, only those articles which derive their aesthetic appeal from their utilitarian application would be denied protection.[120] This would allow other designers to make innovative and creative designs based on underlying functionality, while still preserving protection in the artistic expression of the original designer.[121] B. Requirements for Implementation In creating a copyright system which recognizes the expressions of designers, many old fears, such as burdening the consumer and creating a marketplace monopoly, resurface. With tens of thousands of designers churning out work, it is easy to foresee chaos. How far does the copyright extend? For how long? What would constitute infringement? 1. Scope of Copyright Garments are popular and desirable to the public because of the selection and arrangement of their materials, style and quality. Many of their actual elements are not new expressions, but appropriate ideas within the public domain. No designer would argue that a hem was a new expression, much less a seam or button closure. Like the photograph in Burrow-Giles v. Sarony, it is the selection and arrangement of the finished product which provides value and therefore deserves protection as creative expression.[122] It is also a well-established industry practice to be inspired by the work of other designers when creating your own work.[123] The result is a necessarily thin copyright which provides protection for garment designs from outright theft but does not seek to completely overburden the copyright system.
2. Limited Duration
3. Compulsory License System If copyright is extended to garment designs, it is reasonable to assume that designers will seek protection for their designs and then license them. One of the arguments against extending protection is the potential for large numbers of infringement actions. This problem might be successfully eliminated by incorporating a compulsory license system.[126] Such a system is not new to the world of copyright. It would avoid the need for individual negotiations over license fees and allow small manufacturers to benefit from the work of larger designers.[127] Just as with the compulsory license system for phonorecords, manufacturers who feel that a particular design is valuable would be able to make reproductions of the garment for a statutory fee.[128] Such a license, however, would only allow the manufacturer to make his own interpretation of the design, not an exact replica. Under the current system, this is the same process already followed by some manufacturers: the design is copied and reproduced in different fabrics or with slight changes in the design.[129] In addition to the monetary benefits of a compulsory license system, the system would also reduce the need for a court to foray into the "artistic realm" it so clearly wishes to avoid.[130] V. Effect on Industry The claim of copyright is primarily based on a moral right of the creator of a work and a society's desire to reward this labor. In this case, copyright serves to legitimize the artistic endeavors of the designer. The claim of copyright for garment design, however, is also related to the need for economic incentives.[131] The denial of copyright for clothing has only marginally protected the welfare of the general public and has ignored the need for a designer's economic incentive.[132] It is clear that the lack of copyright protection in the U.S., as well as the existence of protection in Europe, has not changed the ability of designers to create new garments each season. Nor has there been any adverse effect on the power of the public to purchase garments made by quality designers at reasonable prices.[133]
Opponents to the extension of copyright protection for fashion designers argue
that, based on pure statistical information, the lack of copyright protection
has benefited both the public and the apparel industry. Designers have only
had to surrender a small portion of their profits to manufacturers who steal
and reproduce their designs. Further, they argue, the pirate's ability to take
this property from the designers, along with the designer's name, provides
indirect advertising for the designer, which ultimately benefits the designer's
market share. By all accounts, the fashion industry has blossomed in recent
years, and many designers are posting record profits.
If copyright protection is extended to garment designs, it will not likely have significant effect between designers. True, if a designer infringes upon another's work (and there are rumors of designers trying to steal another's "ideas") there can be an action for infringement. However, the case law in Europe indicates that designers understand that there is a certain level of inspiration and similar themes in each season, and have not been suing each other rampantly over infringement. Rather, as the Yves Saint Laurent case shows, an action for infringement arises when there is an exact copy made. By adopting a limited duration and compulsory license system, the fear of increased litigation is put to rest. If there is a particularly valuable design, a manufacturer can simply pay the customary license and produce his own version of the garment. VI. Conclusion The question of whether or not to grant copyright protection should consider the work of the designers and their economic interest, rather than the desires of the general public. The mere fact that an industry has been able to devise other methods of upkeeping its financial stability should not be a reason to deny creative expression protection. By continuing to deny proper protection, economic incentive is displaced to design pirates, who create no new material, thus undermining the copyright policy by adding to the public's cultural welfare. Under a system of copyright protection, the public view on the world of fashion design would not change considerably from the one we all currently know. The number of designers would not increase any more rapidly than it has because the copyright system is not a major economic incentive for fashion designers who have lived so long without it. The basis for granting copyright protection lies in awarding the author a moral right to his creation. In actuality, a garment design copyright only punishes the pirate, who deliberately copies the design, while benefiting the true creators and the public.
[a]Jennifer Mencken, BFA California State
University Fullerton 1992, JD candidate Boston College Law School 1998. The
author wishes to thank Professor Alfred Yen, Kristen Mathews and the IPTF staff
for comments to this paper. |
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