No Copyright in Cardio: Ninth Circuit Rejects Protection for Tracy Anderson Exercise Routines
Can a workout method be protected as choreography under federal copyright law? The Ninth Circuit recently said no.
Without breaking too much of a sweat, the Ninth Circuit, in a trim five-page order, affirmed summary judgment in favor of defendants, celebrity trainer Megan Roup (“Roup”) and her fitness platform, The Sculpt Society (“TSS”), on a copyright infringement claim brought by Tracy Anderson Mind and Body, LLC (“TAMB”), holding that the exercise routines at issue are not protectable works. (Tracy Anderson Mind and Body, LLC v. Roup, No. 24-6936 (9th Cir. Feb. 17, 2026) (unpublished)). The decision reinforces a boundary the Ninth Circuit first articulated a decade ago in the Bikram’s Yoga opinion. In that case, the appeals court confirmed that fitness sequences themselves are generally uncopyrightable methods, processes, or systems that primarily reflect function, not expression (even
