federal court rules bikram choudhury does not hold copyright for series of yoga postures
Ruling in favor of Evolation Yoga confirms Bikram cannot prevent other studios from offering “hot yoga” classes utilizing same 26-posture sequence used in Bikram classes.
Los Angeles, December 17, 2012 – U.S. District Court Judge Otis Wright ruled on Friday that Bikram Choudhury, founder of Bikram’s Yoga College of India, does not have copyright protection for the sequence of 26 yoga postures and two breathing exercises developed by Choudhury and commonly known as “Bikram Yoga.” The ruling, in favor of Evolation Yoga LLC and its founders Mark Drost and Zefea Samson, means that non-Bikram studios can offer “hot yoga” classes utilizing that same 26-posture sequence, a legal right that Choudhury has been actively and vigorously contesting for several years.
Each of the 26 postures is thousands of years old. Choudhury first arranged those specific postures into a sequence in the 1970s and popularized the sequence as “Bikram Yoga,” and he has claimed for decades that he and his affiliated studio owners have the exclusive right to offer yoga classes utilizing the sequence. In 2011, Choudhury filed three federal lawsuits in Los Angeles—including one against Evolation Yoga and its founders—alleging copyright infringement against non-affiliated yoga studios offering classes in which the same or a similar sequence of postures was taught. The owners of the yoga studios involved in the other two cases settled with Choudhury in November 2012. Evolation Yoga and its owners were determined to get a court ruling that resolved Choudhury’s copyright claim once and for all.
Mark Drost, one of Evolation Yoga’s founders, expressed relief for the whole yoga community. “The court’s ruling confirms what we’ve always believed,” according to Drost. “No one person or organization owns yoga or any type of yoga. It belongs to all of us.”
In its ruling granting the Evolation parties’ motion for summary judgment on the copyright issue, the court rejected Choudhury’s claim that Choudhury was previously issued a registration for the sequence, separate and apart from a book Choudhury authored, and the court rejected Choudhury’s claim that the yoga sequence qualified for protection as a work of choreography or pantomime. The court adopted the arguments advanced by the Evolation parties’ attorney Eric Maier of Maier Shoch LLP, granting the motion on the ground that a compilation of yoga poses does not fall within any of the protected categories of works of authorship under the Copyright Act, and on the ground that the sequence developed by Choudhury would be excluded from copyright protection in any event because it is a system or procedure.
Evolation Yoga LLC offers a variety of yoga classes for students and prospective teachers at its facilities in Buffalo, New York; North Tonawanda, New York; Tampa, Florida; and Santa Barbara, California. Evolation also has studio affiliates and conducts teacher trainings in other parts of the US and throughout the world.