Bikram’s Yoga College of India v. Evolation Yoga, LLC

“Ideas can be taught — but not owned.”

Short Description

Bikram’s Yoga College of India v. Evolation Yoga, LLC is a significant copyright law case that clarified the limits of copyright protection over functional systems. The case addressed whether a fixed sequence of yoga poses could be protected under copyright law or whether it constituted an uncopyrightable method or system.

Facts

Bikram Choudhury developed a specific sequence of 26 yoga postures and two breathing exercises, popularly known as Bikram Yoga. He authored books describing this sequence and claimed copyright over the yoga routine.

Evolation Yoga, LLC operated yoga studios that taught the same 26-pose sequence without authorization from Bikram Choudhury. Bikram’s Yoga College of India filed a lawsuit alleging copyright infringement, claiming exclusive rights over the yoga sequence itself.

The defendants argued that yoga poses and sequences are functional methods of exercise and cannot be copyrighted, even if they are described in copyrighted books.

Findings

The court examined the distinction between expression and idea/system under copyright law. It observed that:

⦁ Individual yoga poses are functional movements

⦁ A sequence of poses designed to improve health constitutes a system or method

⦁ Copyright law protects the expression of ideas, not the ideas or systems themselves

⦁ While books and descriptions may be copyrighted, the underlying yoga sequence cannot be monopolized

The court emphasized that granting copyright over exercise systems would improperly restrict public access to functional practices.

Suggestion

Creators of fitness programs and instructional methods should understand that copyright law does not protect systems, methods, or processes. Protection may instead be sought through trademarks, branding, or contractual licensing rather than copyright enforcement.

Judgment

The court ruled in favor of Evolation Yoga, LLC, holding that the Bikram Yoga sequence is a functional system and therefore not copyrightable. Teaching the yoga sequence did not constitute copyright infringement. The court affirmed that copyright law cannot be used to control methods of exercise or physical training.