Editing Copyright misuse (section)

=== ''Practice Management Information Corp. v American Medical Association'' ===
The [[United States Court of Appeals for the Ninth Circuit|Ninth Circuit]] was the next circuit to adopt the copyright misuse doctrine in ''Practice Management Information Corp. v American Medical Association''.<ref>121 F.3d 516 (9th Cir. 1997)</ref> In this case, American Medical Association granted Health Care Financing Administration (now known as the [[Centers for Medicare and Medicaid Services|Centers for Medicare & Medicaid Services]]) a non-exclusive, royalty-free perpetual license to use its coding system for medical procedures.<ref>Ibid. at 517</ref> However, the license was restricted, as no other coding system could be used.<ref>supra note 11 at 520-521</ref> Practice Management, a publisher and distributor of medical books, filed for declaratory relief to have the copyright invalidated when it failed to procure the volume discount it requested.<ref name="n11521">supra note 11 at 521</ref> The Court refused to invalidate the copyright but ruled that the licensing provision requiring exclusive use of the coding system constituted copyright misuse.<ref name="n11521"/>