Rockford Map Publishers, Inc. v. Directory Service Company Of Colorado, Inc.

768 F.2d 145 (1985)

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Nature of the Case

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Facts

P took aerial photographs distributed by the Department of Agriculture and traced the topographical features from the photographs and draws lines showing townships and sections. Then an employee went to the places where land titles are recorded and reads the books. The employee uses the legal descriptions of the deeds to draw boundary lines indicating the location and size of each parcel. He pencils in the name of the owner. From time to time P updates the maps as ownership of land changes. Figure 1 is the result for one township in Ford County, Illinois. P had done this for more than 500 counties throughout the United States. D also publishes plat maps. It starts with a square grid and draws in the information about ownership without regard to topographical features. One day, D enlarged P's plat maps and told its agent to check the records using P's map as a worksheet. D's agent also recorded information about parcels P had deemed too small to put on its plat maps. The agent estimates that she spent 75 hours on these tasks for Ford County. When she was done she sent the corrected plat maps to D, whose staff produced a new map. P knew by looking that its plat maps had been used as templates. Some of the names in Ps maps have bogus middle initials. These initials, if read from the top of the map to the bottom, spell out 'Rockford Map Inc.' D's maps contained 54 of the 56 trap initials. P sued D contending that D violated P's copyrights. The court ruled for P. D appealed. D contends that P's plat maps are not copyrightable.