Mazer v.

Stein
347 U.S. 201 (1954)
FACTS:
Stein created and registered for copyright a Grecian-style sculpture of a woman, which
was then manufactured into a mass-produced lamp base. Mazer subsequently manufactured
similar lamp bases.
Stein filed action for copyright infringement. The trial court found for Mazer on the
grounds that copyrights are not intended to protect utilitarian items such as lamps, resulting in
an appeal by Stein. The appellate court reversed, finding that a subsequent utilization of a work
of art in an article of manufacture does not preclude the copyright owner to be protected from
the infringement of the work itself. Mazer appeals.

This case involves the validity of copyrights obtained by respondents Stein et al. (Stein), a
manufacturer, for statuettes of male and female dancing figures made of semivitreous china.
The controversy centered around the fact that although copyrighted as "works of art," the
statuettes were intended for use and used as bases for table lamps, with electric wiring, sockets
and lamp shades attached. The United States Court of Appeals for the Fourth Circuit that held
that Stein had a valid copyright in statuettes it copyrighted as works of art and, subsequently,
used as bases for table lamps it manufactured and sold. Petitioners Mazer et al., a competitor
manufacturer, sought review of the court of appeals judgment.

ISSUE:
Whether or not Stein is entitled to copyright protection from Mazer’s copy of the lamp
base because the lamp statute qualifies as a “work of art” under U.S Copyright Law?
HELD:
Yes, Stein is entitled to copyright protection from Mazer’s copy of the lamp base
because the lamp statute qualifies as a “work of art” under U.S Copyright Law.
Upon reviewing the history of the successive Copyright Acts and the legislative history,
the Court found that a “work of art” has a broader specification than just a “work of fine art.” A
work that is the result of the original, tangible ideas of the creator is subject to copyright
protection. Thus, the Court finds that the lamp base satisfies the requisite originality needed for
protection.
The Court also reasons that the lamp base, fitted as lamps or unfitted, may be granted a
design patent but patentability does not bar the lamp bases from being copyrighted as a “work
of art. Furthermore, the Court found that the intended or actual use in industry of an article
eligible for copyright does not bar or invalidate its registration. As a result, Stein’s lamp base is
entitled to copyright protection.
An original idea, incorporated into a utilitarian object, may be protected as a “work of
art” under U.S. Copyright Law.
The Court based its decision on the policy reasoning that copyrights are granted (1) to
encourage individual effort by personal gain and (2) to promote advancement of public welfare
through talents of authors and inventors in science and art.

The Court affirmed the order declaring that the copyright was valid. The subsequent use of a
copyrighted work of art in the manufacturing of lamps did not affect respondents' right to be
protected against infringement of the work of art itself. Legislative history of the copyright act
and the practice of the copyright agency showed that works of art and reproductions of works
of art were intended by Congress to be copyrighted. The statuettes were original tangible
expressions of an author's ideas. The reproduction of the statuettes as table lamp bases did not
bar or invalidate the statuettes' registration. Nothing in the copyright statute supported the
argument that the intended use of an article barred or invalidated registration. The Court also
held that the use of a work of art as an element in a manufactured article was not a misuse of
the copyright.