Computer Associates International, Inc. v. Altai, Inc.
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Computer Associates International, Inc. v. Altai, Inc., 982 F.2d 693 (2d Cir. 1992)[1] is a decision from the United States Court of Appeals for the Second Circuit that addressed to what extent non-literal elements of software are protected by copyright law. The court used and recommended a three-step process called the Abstraction-Filtration-Comparison test. The case was an appeal from the United States District Court for the Eastern District of New York in which the district court found that defendant Altai's OSCAR 3.4 computer program had infringed plaintiff Computer Associates' copyrighted computer program entitled CA-SCHEDULER.[1] The district court also found that Altai's OSCAR 3.5 program was not substantially similar to a portion of CA-SCHEDULER 7.0 called SYSTEM ADAPTER, and thus denied relief as to OSCAR 3.5. Finally, the district court concluded that Computer Associates' state law trade secret misappropriation claim against Altai was preempted by the federal Copyright Act.[1] The appeal was heard by Judges Frank Altimari, John Daniel Mahoney, and John M. Walker, Jr. The majority opinion was written by Judge Walker. Judge Altimari concurred in part and dissented in part. The Second Circuit affirmed the district court's ruling as to copyright infringement, but vacated and remanded its holding on trade secret preemption.[1]
Computer Associates International, Inc. v. Altai, Inc. | |
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Court | United States Court of Appeals for the Second Circuit |
Full case name | Computer Associates International, Inc. v. Altai, Inc. |
Argued | January 9, 1992 |
Decided | June 22, 1992 amended: December 17, 1992 |
Citation(s) | 982 F.2d 693; 119 A.L.R. Fed. 741; 61 USLW 2434, 37 Fed. R. Evid. Serv. 348 |
Holding | |
The court applied the Abstraction-Filtration-Comparison, three-step test to determine whether substantial similarity is met when proving copyright infringement for non-literal elements of software, and it held that Altai's rewritten code did not meet the requirements for copyright infringement, and vacated and remanded the ruling on trade secret misappropriation. | |
Court membership | |
Judge(s) sitting | Frank Altimari, John Mahoney, and John Walker |
Keywords | |
copyright infringement, non-literal elements, substantial similarity, abstraction-filtration-comparison |