Computer Associates Int. Inc. v. Altai Inc.
| Computer Associates International, Inc. v. Altai, Inc. | |
|---|---|
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| Court | United States Court of Appeals for the Second Circuit |
| Full case name | Computer Associates International, Inc. v. Altai, Inc. |
| Decided | June 22, 1992 |
| Citation(s) | 982 F.2d 693; 119 A.L.R. Fed. 741; 61 USLW 2434, 37 Fed. R. Evid. Serv. 348 |
| Case opinions | |
| This case presents a three-step test, Abstraction-Filtration-Comparison, to determine whether substantial similarity is met when proving copyright infringement for non-literal elements of software. The court held that Altai's rewritten code did not meet the requirements for copyright infringement, and vacated and remanded the ruling on trade secret misappropriation. | |
| Court membership | |
| Judge(s) sitting | Frank Altimari, John Mahoney, and John Walker |
| Keywords | |
| copyright infringement, non-literal elements, substantial similarity, abstraction-filtration-comparison | |
Computer Associates International, Inc. v. Altai, Inc., 982 F.2d 693 (2d Cir. 1992) is a decision from the United States Court of Appeals for the Second Circuit that addressed to what extent non-literal elements of software are protected by copyright law. The court used and recommended a three-step process called the Abstraction-Filtration-Comparison test. The case was an appeal from the United States District Court for the Eastern District of New York in which the district court found that defendant Altai's OSCAR 3.4 computer program had infringed plaintiff Computer Associates' copyrighted computer program entitled CA-SCHEDULER. The district court also found that Altai's OSCAR 3.5 program was not substantially similar to a portion of CA-SCHEDULER called ADAPTER, and thus denied relief as to OSCAR 3.5. Finally, the district court concluded that Computer Associate's state law trade secret misappropriation claim against Altai was preempted by the federal Copyright Act. The appeal was heard by Judges Frank X. Altimari, John Daniel Mahoney, and John M. Walker, Jr. The majority opinion was written by Judge Walker. Judge Altimari concurred in part and dissented in part. The Second Circuit affirmed the district court's ruling as to copyright infringement, but vacated and remanded its holding on trade secret preemption.
Computer Associates (CA) created a job scheduling program called CA-SCHEDULER which sorts, runs, and controls the various tasks given to a computer. This scheduler was designed to be compatible with IBM System 370 computers which ran one of three different operating systems: DOS/VSE, MVS, and VM/CMS. Traditionally, a program must be specifically compiled to run on a designated operating system. In order to allow the same code to run on the different operating systems, the CA-SCHEDULER included a component called ADAPTER that was designed to translate the language of the program into commands understandable to that particular operating system. This way the CA-SCHEDULER could use the same code but run on different operating systems.
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