L. Batlin & Sons, Inc. v. Snyder
United States Court of Appeals for the Second Circuit
536 F.2d 486 (1976)
After the patent on the classic metal Uncle Sam mechanical bank expired, placing its design in the public domain, Jeffrey Snyder (defendant) contracted with a Hong Kong company to produce a smaller plastic version with minor changes - such as an eagle holding leaves instead of an arrow, changed because the arrow shape did not render clearly in plastic at the smaller scale - and obtained a copyright registration for his version. When L. Batlin & Sons, Inc. (Batlin) (plaintiff) tried to import competing Uncle Sam banks, Customs blocked the shipment based on Snyder's copyright, and Batlin sued for a declaration invalidating it; the district court granted Batlin a preliminary injunction, and Snyder appealed.
Whether a reproduction is copyrightable if the reproduction neither requires a high degree of skill in scaled duplication nor includes a substantial variation from the original.