Are You Infringing Copyright With That Sequence Of Yoga Poses?

Breathe easy: the US district court in Los Angeles has decided that the answer is no. Bikram Choudhury and his yoga college contended otherwise, arguing that copyright in a sequence of 26 poses, performed in a particular order and in a room heated to 105 degrees Fahrenheit, was being violated by Evolation Yoga, an operation run by two former Choudhury employees: Bikram's Yoga College of India LP v Evolation Yoga LLC (Cent D Calif, 14 December 2012). Choudhury had registered copyright in written and audiovisual materials describing the sequence and contended that this extended to the moves themselves. A notion which Wright J rejected, citing the classic decision in Feist Publications Inc v Rural Telephone Service Co, 499 US 340 (1991): Choudhury's copyright protected the expression of the sequence but not the underlying facts of the sequence itself. And anyway, a system of exercises or yoga poses is not copyrightable subject matter under US legislation, not even as a