Meshwerks' products was attributable to the Toyota designers who conceived of the vehicle designs in the first place; accordingly, defendants' use of the models could not give rise to a claim for copyright infringement.
The district court agreed. It found that the wire-frame models were merely copies of Toyota’s products, not sufficiently original to warrant copyright protection, and stressed that Meshwerks' "intent was to replicate, as exactly as possible, the image of certain Toyota vehicles." D. Ct. Op. at 8. Because there was no valid copyright, there could be no infringement, and, having granted summary judgment on the federal copyright claim, the district court declined to exercise supplemental jurisdiction over Meshwerks' state-law contract claim. Today, Meshwerks asks us to reverse and hold its digital, wire-frame models sufficiently original to warrant copyright protection.[1]
II
To make a case for copyright infringement, Meshwerks must show (1) it owns a valid copyright, and (2) defendants copied constituent elements of the work that are original to Meshwerks. Autoskill Inc. v. Nat'l Educ. Support Sys., Inc., 994 F.2d 1476, 1487 (10th Cir. 1993). Our inquiry in this case focuses on the first of these tests – that is, on the question whether Meshwerks held a valid
- ↑ On appeal, we have not been asked to address Meshwerks' contract claim, though if the holding on its federal claim were to be reversed, the existence of supplemental jurisdiction to review the contract claim of course would have to be reconsidered.
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