Home Legend, LLC v. Mannington Mills, Inc.

Docket Number: 14-13440
Judge: Edward Earl Carnes
Opinion Date: April 29, 2015

Mannington Mills, Inc. appealed the grant of summary judgment in favor of Home Legend, LLC, that Mannington’s registered copyright in its “Glazed Maple” design was invalid. Mannington and Home Legend both sold laminate wood flooring. The copyright at issue in this case covers Mannington’s decor paper design called “Glazed Maple,” which is a huge digital photograph depicting fifteen stained and apparently time-worn maple planks. That appearance was only an appearance. In 2008, three Mannington employees created the Glazed Maple design not from aged planks but from raw wood. The team did not seek out an actual aged wood floor from which to create the design but instead “envision[ed what] a floor could look like after” twenty or thirty years, including the effects “age and wear and patina” might have on the planks. The United States Register of Copyrights registered Mannington’s copyright in its Glazed Maple design in November 2010. In September 2012, Mannington discovered that its competitor Home Legend was selling laminate flooring products with designs that it alleges were “virtually identical in every respect” to the Glazed Maple design. Mannington requested that Home Legend stop selling the allegedly infringing products. Home Legend responded by filing suit in the district court, seeking a declaratory judgment that Mannington’s copyright was invalid. Mannington counterclaimed for copyright infringement and moved for a preliminary injunction, a motion that the district court denied. At the close of discovery, Home Legend moved for summary judgment, arguing that Mannington’s registered Glazed Maple copyright did not cover copyright-eligible subject matter. The district court granted summary judgment to Home Legend on three alternative grounds. The Eleventh Circuit reversed, finding: Mannington owned a valid copyright, “even if the protection that copyright affords it is not particularly strong.” Because much of the expression in Mannington’s finished Glazed Maple design still reflected the uncopyrightable features of each plank, Mannington’s copyright gives it the limited protection of a derivative work. View “Home Legend, LLC v. Mannington Mills, Inc.” on Justia Law

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