ATC Distribution Group, Inc. v. Whatever It Takes Transmissions & Parts, Inc.
United States Court of Appeals for the Sixth Circuit
402 F.3d 700 (2005)
ATC Distribution Group, Inc. (ATC) (plaintiff) bought another company's transmission-parts business, including a catalogue that assigned part numbers by brand, transmission type, and part type, leaving blocks of unused numbers for future products. A former ATC employee, Kenny Hester, left to start a competing company, Whatever It Takes Transmissions & Parts, Inc. (WITT) (defendant), and used a copy of ATC's catalogue to build a similar one for WITT. ATC sued WITT for copyright infringement of the numbering system. The district court granted summary judgment for WITT, and ATC appealed.
Whether a part-number classification system is an idea under 17 U.S.C. § 102(b), subject to the merger doctrine, and therefore ineligible for copyright protection.