The case concerned the rights to publish an unpublished article, “Psychopathology of Awareness,” written by Dr. Frederick Perls. Dr. Perls’s widow, Laura Perls, inherited the copyright to this article. In 1991, her estate entered an agreement with the Center for Gestalt Development, granting the Center exclusive rights to publish a collection of Dr. Perls’s unpublished manuscripts, which included the article. However, the Center did not publish the collection until 2021. In the mid-2010s, Charles Bowman acquired a copy of the article and, together with Jean-Marie Robine, decided to publish it with additional commentary. Before publishing, Bowman and Robine sought and received permission from Dr. Perls’s children, who had inherited the copyright to the article itself, to include it in their book.

After learning of Bowman and Robine’s plans, the Center contacted them to assert its own purported rights, but the Center refused their offers of collaboration. Bowman and Robine then obtained an oral license from the Perls siblings, communicated through Leslie Gold, authorizing them to use the article. In 2021, following litigation, the Perls siblings assigned their rights in the article to the Center until the conclusion of this lawsuit.

The Center sued Bowman and Robine for copyright infringement in the United States District Court for the Southern District of Indiana. The district court found that the Center’s 1991 agreement conveyed rights only in the collection as a whole, not in the article individually. It further determined that Bowman and Robine had an irrevocable oral license to use the article before the Center acquired the copyright.

The United States Court of Appeals for the Seventh Circuit affirmed the district court’s entry of summary judgment for Bowman and Robine. The main holding was that ownership of a compilation copyright does not confer rights in the individual components, and the oral license granted to Bowman and Robine precluded infringement claims by the Center. View “Center for Gestalt Development, Inc. v Bowman” on Justia Law