the way for a new and unanticipated application of Whelan. Under Broderbund, software designers will not be able to market programs which use the same, or a substantially similar, user interface ... [T]he ... decision extended copyright protection to a program's menu screens 'without regard for the lack of similarity in the underlying code. In Digital Communications Associates v. Softklone (1987) the court rejected Broderbund, holding that showing screen replication was not sufficient. The plaintiff had to show that the source or object code had substantial similarities. The Copyright Office refused to register copyright in the textual display screens of the Lotus 1-2-3 spreadsheet software in 1987. On 8 June 1988 the Copyright Office issued a Notice of Decision, summarized as: Other courts, such as the District Court of Connecticut in Manufacturers Technologies, Inc. v. CAMS Inc. (1989), found that the Broderbund approach was too expansive. That court decided that the software and the user interface were distinct, although could each contain copyrightable material, so the program accomplished "two interrelated yet distinct registrations." The court decided to review each screen, determine whether it contained expression that could be separated from the purpose or idea underlying the screen, and if so determine whether that expression had been copied. Taking this more detailed approach, the court found that some aspects such as the method of formatting a screen or of navigating within a screen were not subject to copyright, but other aspects of the screen appearance were copyrightable expression. References Citations Sources External links United States copyright case law United States District Court for the Northern District of California cases 1986 in United States case law