Lotus Dev. Corp. v. Borland Int'l, Inc.

Corp. v. Borland Int'l, Inc., 516 U.S. 233 (1996), is a United States Supreme Court case that tested the extent of software copyright.

[1] The lower court had held that copyright does not extend to the user interface of a computer program, such as the text and layout of menus.

[2] Quattro Pro also contained a "Key Reader" feature, which allowed it to execute Lotus 1-2-3 keyboard macros.

To support this feature, Quattro Pro's code contained a copy of Lotus's menu hierarchy in which each command was represented by its first letter instead of its entire name.

Borland appealed the decision of the district court arguing that the menu hierarchy is a "method of operation", which is not copyrightable according to 17 U.S.C.

Without the menu command hierarchy, users would not be able to access and control, or indeed make use of, Lotus 1–2–3's functional capabilities.

Likewise, the menu commands, including the textual labels and the hierarchical layout, are essential to operating Lotus 1-2-3.

If menu hierarchies were copyrightable, users would be required to learn how to perform the same operation in a different way for every program, which the court finds "absurd".

[1] Because the Court split evenly, it affirmed the First Circuit's decision without discussion and did not establish any national precedent on the copyright issue.

By the time the lawsuit ended, Borland had sold Quattro Pro to Novell, and Microsoft's Excel spreadsheet had emerged as the main challenger to Lotus 1-2-3.