The layout of personal planners is an “idea” and not an “expression”—and is thus not protected by copyright law according to the Tenth Circuit. Although EC Design’s personal planners (called the Erin Condren LifePlanner) were the subject of copyright registrations, the court held that the layout of the planners was not protected, so a competitor, Craft Smith, could freely copy it. Moreover, while there was evidence of significant sales by EC Design and intentional copying by Craft Smith, the court found that EC Design had no trade dress rights in the layout of its LifePlanners.
