## Facts

- Utopia owned rights to “ED Maximus,” a set of about 60 emergency-department chart templates used by physicians to document patient encounters.
- The templates consisted largely of headings, categories, and prompts with spaces or check-box style areas for recording patient-specific information.
- Utopia granted Pro-Med a royalty-bearing license to market and use the templates (including in paper and electronic products) and to pay royalties under specified terms.
- Pro-Med developed and marketed products incorporating the template content, including an electronic physician documentation system.
- Utopia alleged Pro-Med continued using derivative products without authorization and failed to pay required royalties, asserting copyright infringement and related state-law claims.
- The district court granted summary judgment to Pro-Med on copyright infringement (finding the templates uncopyrightable blank forms) and dismissed the remaining state-law claims without prejudice after declining supplemental jurisdiction.

## Issues

1. Whether the ED Maximus chart templates are copyrightable expression or uncopyrightable “blank forms” designed for recording information.
2. Whether the district court abused its discretion by declining supplemental jurisdiction over the remaining state-law claims after resolving the federal copyright claim.
3. Whether Utopia’s state-law contract-based claims are preempted by the Copyright Act.

## Decision

- The Eleventh Circuit affirmed summary judgment for Pro-Med on copyright infringement, holding the templates were uncopyrightable blank forms.
- The court affirmed the dismissal without prejudice of the state-law claims, holding the district court acted within its discretion in declining supplemental jurisdiction after the federal claim was resolved.
- The court rejected Pro-Med’s cross-appeal on preemption, holding the contract claim contained an extra element (contractual promises, including royalty obligations) and therefore was not preempted.

## Legal Principles

- Blank forms that merely provide categories and spaces for recording information, without conveying original expression, are not copyrightable.
- Functional headings and prompts reflecting standardized subject-matter organization generally do not supply the originality needed to avoid the blank-forms rule.
- A district court may decline supplemental jurisdiction over state-law claims once all federal claims have been dismissed, particularly where the remaining dispute centers on state contract and related obligations.
- Copyright Act preemption applies only when a state claim asserts rights equivalent to copyright; contract claims based on bargained-for promises (e.g., license terms and royalty duties) include an extra element and are typically not preempted.

## Conclusion

The court held that physician charting templates organized as headings and prompts for recording patient data are uncopyrightable blank forms, affirmed the federal court’s decision to leave the remaining contract and related disputes to state court, and ruled that the contract claim was not preempted because it rested on obligations created by the parties’ license agreement.


Utopia Provider Systems, Inc. v. Pro-Med Clinical Systems, L.L.C., 596 F.3d 1313 (11th Cir. 2010)