RJ Control Consultants, Inc. v. Multiject, LLC, 981 F.3d 446

Rogers (RJ Control) developed a rotary turntable control system (“Design 3”) for Multiject; Rogers provided technical drawings and full source code to Multiject in March 2014.
Days later Multiject replaced Rogers with RSW for assembly/wiring; RSW used Design 3 (code and drawings) without changes; RSW says it believed it had permission.
Rogers obtained two copyright registrations in Feb 2016: one for the software and one for the technical drawings, then sued Multiject, Elder, and RSW for copyright and other claims.
The district court granted summary judgment to defendants: dismissed copyright and trademark claims with prejudice, declined supplemental jurisdiction over state-law claims, and denied a motion to compel as moot.
On appeal, the Sixth Circuit affirmed that using copyrighted technical drawings to manufacture the depicted useful article is not copyright infringement, reversed as to the software copyright, and remanded for further factfinding (including expert evidence); it vacated in part and affirmed in part the denial of the motion to compel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether copying/using copyrighted technical drawings to build the control system is actionable copyright infringement	Rogers: access + substantial similarity; using the drawings to reproduce the device is copying	Defendants: drawing depicts a useful article; using it to make the machine is not copyright infringement and is a patent-style claim	Held: Use of Design 3 drawings to manufacture the control system is not copyright infringement; patent, not copyright, protects functional use
Whether the software source code is copyrightable and whether defendants infringed it	Rogers: the code is protected expression; defendants copied it	Defendants: the code primarily embodies procedures/systems/methods (uncopyrightable); many lines may be functional or standard	Held: Reversed summary judgment as to software. Copyrightability requires line-by-line filtering (merger, scenes a faire); factual issues remain and expert evidence is needed; remand for further proceedings
Whether denial of plaintiffs’ motion to compel discovery as moot was proper	Rogers: discovery was necessary for the software claim and for reconsideration	Defendants: motion mooted by summary judgment	Held: Denial vacated to the extent the discovery was relevant to the surviving software copyright claim; other discovery related to drawings/state claims remains moot

Lexmark Int’l, Inc. v. Static Control Components, Inc., 387 F.3d 522 (6th Cir. 2004) (sets two‑part infringement test and discusses filtering unprotectable elements in software)
Feist Publ’ns, Inc. v. Rural Tel. Serv. Co., 499 U.S. 340 (1991) (copyright protects expression, not facts or ideas)
Baker v. Selden, 101 U.S. 99 (1880) (distinguishes copyright protection of expression from patent protection of methods/use)
Sega Enters., Ltd. v. Accolade, Inc., 977 F.2d 1510 (9th Cir. 1992) (discusses idea/expression issues and scènes à faire in software)
Atari Games Corp. v. Nintendo of Am. Inc., 975 F.2d 832 (Fed. Cir. 1992) (legislative history and application of §102(b) to computer programs)
Mazer v. Stein, 347 U.S. 201 (1954) (copyright protects expression, not the art or useful article itself)
Robert R. Jones Assoc., Inc. v. Nino Homes, 858 F.2d 274 (6th Cir. 1988) (architectural plans context; distinguished from non‑architectural technical drawings)