Rejection of Bikram Copyright Upheld in Appellate Court

October 8, 2015

On Oct. 8, the Ninth Circuit Court of Appeals in California affirmed a previous ruling by a federal district court that Bikram Choudhury’s sequence of 26 yoga poses is not entitled to copyright protection.

Writing for the three-judge panel, Judge Wardlaw wrote:

“We must decide whether a sequence of twenty-six yoga poses and two breathing exercises developed by Bikram Choudhury and described in his 1979 book, Bikram’s Beginning Yoga Class, is entitled to copyright protection. This question implicates a fundamental principle underlying constitutional and statutory copyright protection—the idea/expression dichotomy. Because copyright protection is limited to the expression of ideas, and does not extend to the ideas themselves, the Bikram Yoga Sequence is not a proper subject of copyright protection.”

The Court affirmed that, although Bikram Choudhury held copyright protection in his published book on his Sequence, he could not thereby invoke copyright to stop others from using the sequences described in his book.

Yoga Alliance, through its counsel Pillsbury Winthrop Shaw Pittman LLP, supported appellee Evolation Yoga, the subject of the Bikram Choudhury’s legal challenge. We provided copyright expertise and filed an amicus brief in the Ninth Circuit in support of the principle that a sequence of yoga poses is not protectable by copyright.

On behalf of the entire yoga community, Yoga Alliance is proud to have been able to contribute to the positive resolution of this this troubling issue. Yoga instructors can now put together a sequence of yoga poses without fear of infringing copyrights.

For more details, read the full Opinion.