Walter v. Lane

Walter v. Lane [1900] AC 539, (House of Lords) — a precedent in the Commonwealth countries that recognized fixation could be a determining factor in copyright determinations.

Facts: A speech is given in public by a politican. A newspaper hires skilled shorthand note-takers to record it, and publishes the speech. Some time later, another book publisher prints a collection of the politican's speeches. The newspaper sues the book publisher.

Result: Copyright is held by reporters who put politician's speech in material form.

Reasoning: The note-takers were skilled participants placing the work in material form, the politican was not involved in the case and the court awarded the copyright to the newspaper.