Roth Greeting Cards v. United Card Co.
United States Court of Appeals for the Ninth Circuit
429 F.2d 1106 (1970)
Roth Greeting Cards (plaintiff) sued United Card Company (defendant) for producing seven greeting cards that closely copied Roth's cards, including identical captions and inside messages paired with nearly identical cartoon artwork, differing only in minor color and style details. The trial court found Roth's artwork copyrightable but held United's cards non-infringing because the wording alone used common, public-domain English phrases; Roth appealed, arguing the combined arrangement of text and artwork as a whole deserved protection.
Whether copyright protects the arrangement of particular textual wording combined with associated artwork that together create the tangible expression of an idea, even when the wording alone is not original.