1930),[1] was a United States Court of Appeals for the Second Circuit case on copyright infringement by non-literal copying of a dramatic work.

The Court held that copyright protection cannot be extended to the characteristics of stock characters in a story, whether it be a book, play, or film.

A lawsuit followed, with the plaintiff asserting copyright infringement based on the defendant's use of similar story elements.

Judge Learned Hand, writing for the Court, noted that protection of literature cannot be limited to the exact text, or else an infringer could get away with copying by making trivial changes.

However, it is impossible to set a firm boundary demarcating the line between work and ideas, he said, stating, "her copyright did not cover everything that might be drawn from her play; its content went to some extent into the public domain."