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Stephanie Hays and Gail MacDonald v. Sony Corporation of America
Court of Appeals for the Seventh Circuit (1988) | 847 F.2d 412
TL;DR: High school teachers sued Sony for copying a word-processing manual they wrote. The court found their statutory copyright claim was not frivolous due to ambiguity in the “work for hire” doctrine, but affirmed sanctions against their attorney for pursuing other baseless claims and failing to investigate.
Legal Significance: This case provides a significant judicial analysis of the “work made for hire” doctrine under the 1976 Copyright Act, questioning whether the traditional “teacher exception” survived the statute's enactment and clarifying that a non-frivolous core claim does not excuse surrounding frivolous litigation conduct.