T-shirt Print and the blurry line between copyright trademark unfair competition

From: Adam Grossman <grossman22[_at_]hotmail.com>
Date: Tue, 19 Apr 2005 17:10:01 -0400


In looking into opening a small business printing t-shirts and other similar products I have begun researching copyright law. In doing this I have found that in the context of printing (onto t-shirts, sweaters, bags, hats, ect.) copyright law and intellectual property protection have become, at least in my opinion, very complex. Especially today with small screen-printing businesses being so popular among people who wish to start small businesses.   So now I wish to give several examples and questions that can be raised with them, along with my own insights into them. Example 1: T-shirts that say ¡°Everyone Loves An Asian Girl¡± or ¡°catholic girl¡± or ¡°Irish girl¡± or any other variation of this phrase. I have seen several companies print the version referring to Asian girls, some showing a copyright notice next to the phrase, some with no copyright notice. Also some tweak the way it is printed slightly. The wording may be exactly the same but the font size, color, and/or style change. Like one shirt having the phrase printed in black times new roman font, and another printed in red
¡°Asian¡± style (letters composed of brush strokes) font. While some may or
may not also have some kind of design surrounding or placed near the phrase.   As far as I can tell many of these companies are printing the t-shirts themselves, whether or not all these companies printing the phrase are paying royalty rights or have some form of agreement with a copyright holder I don¡¯t know.
Questions and Insights: Under US Copyright law you cannot own a copyright to any name, title, or phrase. So me saying and using the phrase as an example does not qualify as copyright infringement, also coupled with the fact that I am using a different medium, and am not making any financial gain from it¡¯s use. Trademark law also doesn¡¯t apply with these or most any other comical phrase you see on t-shirts because they do not advertise the source of goods, or services. If the name of the company printing them was ¡°Everyone Love¡¯s An Asian Girl¡± then that might be plausible. But for companies that make t-shirts with comical phrases this is not plausible because it would be very difficult or impossible for them to market each phrase on the t-shirts as to qualify them as trademarks and therefore entitled to protection. So in what way, shape, or form do any of these companies have entitlement to copyright protection of this phrase if at all?   Is changing the font in way of size, color, and/or style, or adding/deleting other graphics, or where the phrase is placed on the shirt enough to differentiate one shirt from another so it isn¡¯t infringement? Say two companies print the phrase in the same wording and exact same font size, color, and style in the same place on the shirt, do either one of them have right bring charges of infringement upon the other? As I see it, the only possible answer as to how any of these companies can have any form of copyright protection is in the form of expression. An idea cannot be copyrighted and protected, but the form of expression of said idea may be copyrighted and protected. So do these simple phrases qualify as an
¡°idea¡± and therefore you can own a copyright to them being printed on
apparel? If so, does this also give you ownership of derivatives of original phrase being printed onto apparel (i.e. Everyone Loves An Irish Girl/Italian Girl/Southern Girl ect.)? Another possible way for one to protect ones self in this sense may be unfair competition law, but I have not been able to find much to concretely apply to this example. I see this as an important thing to look into and find answers for because there are so many small businesses printing comical phrases on t-shirts today it is difficult to tell if a particular phrase has already been printed before. Even with extensive searches of the internet, copyright, and trademark databases, there is no way for one to know for sure if their idea for a comical phrase to print has already been printed. And despite the enormous popularity and sales many of these comical phrases have, usually they are still very simplistic. This makes it rather likely that multiple people in multiple locations can think of the exact same phrase independent of each other. In searching these forums¡¯ archives I have found some discussion of this topic, but not much in terms of an answer to this question. The answers given to people asking if they could copyright their idea for a t-shirt or bumper sticker seemed to brush it off into the arena of trademarks and unfair competition law. But things such as these don¡¯t seem to qualify as either copyrights or trademarks, or at least in the conventional forms of the two.
If someone does print t-shirts with the same or similar comical phrase, does that give the original author of the phrase protection under unfair competition law? How much would the phrase or the way the phrase is written need to be changed to not be considered unfair competition? Since you cant own a copyright on a phrase, and since such comical phrases don¡¯t indicate a source of good or services and therefore are not trademarks, is it just the form of expression as in printing a comical phrase on t-shirts protected by unfair competition law? If so how do you originally receive protection in any form of registration? Do you register the phrase as a design for a t-shirt, and then only in printing it on t-shirts for sale are you protected? How far can your protection under unfair competition law reach? For a very plain example if I where print t-shirts in Wisconsin (where I am a resident) that read ¡°I went to Madison and bought this shirt¡± would someone printing and selling shirts that read the same but instead of
¡°Madison¡± they wrote ¡°Milwaukee¡± would that be unfair competition? Or
only if I was selling the same such t-shirts in Milwaukee as well. If it gives me a form of protection on obvious derivatives of the original phrase (like just changing the name of the city) would it extend outside of the state? Especially if the shirts became popular and I would want to start selling derivatives of the original phrase in other cities around the Midwest or the whole country, where the name of the city would correspond with the place it is being sold.
I realize that this is very long and many questions. But I see this as a very relevant topic of discussion in copyright law in America today. And I felt only through long explanations and examples (of both real and theoretical t-shirts) could the issue really be addressed and possibly answered. When I started looking into the subject it was just to know how to protect myself legally incase I ever printed something, which I did not know had already been printed. But it has turned into something I personally find very interesting and am continually searching for an answer to.



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