Name: Computer Management Assistance Co. v. Robert de Castro
Cite: 220 F.3d 396
Cite: 220 F.3d 396
- Facts: Computer Management Assistance Co. (CMAC) developed a computer program named ACCESS, which is a pricing system designed to assist distributors in managing sales and facilitating consumer transactions. In 1983, CMAC licensed a copy of ACCESS to Robert deCastro Inc. to use for his distribution business including numerous restrictions on deCastro’s right to use and disclose ACCESS. Included in deCastro’s purchase of ACCESS, an interpreter was also included in the package. This interpreter translates instructions that are in a specific program language into executable code. deCastro subsequently allowed another software manufacturer, Information Management Consultants (IMC), to modify the ACCESS interpreter to use for their own FACTS software. The modifications consisted of altering approximately 750 lines of code, a minute amount in the 600,000+ lines of code in the full program. CMAC filed suit against deCastro and IMC for copyright infringement, trade secret misappropriation, unfair and deceptive trade practices, and breach of contract.
- Procedural History: The United States District Court for the Eastern Division of Louisiana entered judgment against CMAC after a two week bench trial, in addition to awarding attorneys fees against CMAC. CMAC appeals the dismissal of its claims against IMC.
- Issue: Whether the amount of change to the program at hand should be considered an unauthorized copy of a copyrighted work.
- Holding: The court held that the FACTS program and the ACCESS program were only similar for the reason that they serve deCastro’s accounting needs. CMAC presented no convincing evidence proving that FACTS was substantially similar to ACCESS in any copyrightable area of the program. In order to analyze IMC's usage, the court used the abstraction-filtration method. This method consists of three factors that the court looks at to determine whether something is a copy. The three factors that the court considered were: 1) Dissecting the program based on levels of generality, 2) Filter unprotectable elements at each level, and 3) Compare the remaining copyrightable elements to the substantial elements of plaintiff’s program. Upon review of these three factors, this court affirmed the district courts' ruling.