A Baltimore artist named Frederick Bouchat designed what eventually became the Baltimore Ravens’ first logo, but the team used the design from 1996 to 1998 without compensating or crediting Bouchat. After Bouchat successfully sued the team for copyright infringement, the Ravens switched to their current logo after the 1998 season.
Despite the Baltimore Ravens changing the logo design, Bouchat sued the Baltimore Ravens several more times, claiming that the Baltimore Ravens continued to use the original logo that he had designed. Specifically, Bouchart complained that the logo he designed still appeared in highlight reels and in historical photos that were displayed in the Baltimore Ravens’ stadium.
A United States District Court Judge dismissed the suits filed by Bouchat on the grounds that the appearance of the Bouchat logo in highlight reels and in historical photos was allowable under the “fair use doctrine”.
Bouchat appealed to the United States Court of Appeals for the Fourth Circuit, and in December 2013, the Fourth Circuit agreed, saying that the “fleeting and insubstantial” appearance of the logo in the videos and photos did not amount to copyright infringement. “Society’s interest in ensuring the creation of transformative works incidentally utilizing copyrighted material is legitimate no matter who the defendant may be,” the court wrote.
What is the “fair use doctrine” and what interests are the “fair use doctrine” intended to protect?