Religious Technology Center v. Lerma,

40 U.S.P.Q.2d 1569 (1996)

Facts

Lerma (D) acquired texts of the Church of Scientology that the church considered sacred. The Church (P) charged that D had acquired the texts and distributed them in an unauthorized manner. D claimed that the ideas in the works could not be copyrighted and that his publication of the materials was not a violation of the copyright act under the doctrine of merger and that even if copyrightable that his use was fair use.