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The Fight For Religious Freedom: Ananda Wins 95% of the 12-Year Lawsuit Instigated by Self-Realization Fellowship

On December 16, 2002 the Federal District Court in Sacramento entered a Final Judgment officially terminating Self-Realization Fellowship’s (SRF) lawsuit against Ananda Church of Self-Realization (Ananda).

The Judgment came after the jury rendered its verdict on copyrights in 50-year-old writings and sound recordings by the Indian guru Paramhansa Yogananda. Thus ended a 12-year legal battle instigated by SRF.

The case began in 1990 after Ananda added the term "Self-realization" to its name. Self-Realization Fellowship responded by filing a massive lawsuit for trademark, publicity rights, and copyright infringement.

After filing the lawsuit, SRF registered trademarks for the words "Self-realization," a common spiritual term, and "Paramahansa Yogananda," the name of the common guru of SRF and Ananda.

By October 2002, when the case came to trial in United States District Court in Sacramento, 85% of it had already been conclusively decided in Ananda’s favor, according to Federal Judge Edward J. Garcia, who had presided over the case since the beginning.

The jury decided the remaining issues of the case, mostly in Ananda’s favor. In total, Ananda won over 95% of the case.

The jury found that although SRF owned the copyrights for Yogananda’s writings published in its magazines, Ananda’s religious, members-only, and non-commercial use of those writings constituted a “fair use." This decision was tantamount to a verdict of "not guilty of copyright infringement.”

Accordingly, the jury refused to give Self-Realization Fellowship any of the $6 million in damages it sought against Ananda. The law on fair use did not, however, apply to sound recordings, so the jury awarded SRF the nominal sum of $29,000 on their claim that Ananda infringed on the rights to certain recordings of Yogananda’s voice.

During the trial SRF had abandoned its claim to copyrights of numerous photos of Yogananda. Thus, Ananda also prevailed on those claims.

Ananda’s previous legal victories during the 12 year battle were not affected by the final verdict. These include:

  • Self-Realization Fellowship’s trademarks of the term "Self-realization" were cancelled.

Ananda presented voluminous evidence of the term’s generic nature. Thirty-five American Hindu-Yoga organizations submitted statements supporting Ananda’s position.

  • Self-Realization Fellowship’s trademarks of the name "Paramahansa Yogananda" were cancelled.
  • Self-Realization Fellowship’s claim that Ananda was trying to "pass itself off as Self-Realization Fellowship” was dismissed.
  • Self-Realization Fellowship’s claim that “its reputation would be tarnished" if it was confused with Ananda was dismissed.
  • The Court ruled that Self-Realization Fellowship did not own Yogananda’s publicity rights. Self-Realization Fellowship’s claim was based on a California law that gives the heirs of celebrities control over their name, likeness, and voice.
  • The Court ruled that Self-Realization Fellowship did not own the copyrights for certain books Yogananda published before his passing. Based on this decision, Ananda was able to publish the first edition of Yogananda’s Autobiography of a Yogi.
  • The Court ruled that Self-Realization Fellowship did not own the copyrights in various photos of Yogananda.

Twice during the 12-year course of the lawsuit, Self-Realization Fellowship filed appeals to the Ninth Circuit Court of Appeals:

  • In 1994 SRF appealed the cancellation of its trademarks in "Self-realization" and "Paramahansa Yogananda."
  • In 1998 SRF appealed copyright rulings in Ananda’s favor on books, photos, writings published in its magazines and sound recordings.

SRF lost the appeal on books and some of the photos, but won the right to a jury trial on the writings in 50-year-old magazines and sound recordings. SRF unsuccessfully petitioned the United States Supreme Court to review the copyright rulings. At trial, SRF’s claims for the remaining photos of Yogananda were dismissed.

For those who like to read legalese, here’s the pertinent language from the Final Judgment ending the case:

"Judgment now having been entered on all legal and equitable claims in this action, this document, in combination with the Judgment entered October 29, 2002 in accordance with the jury verdict and the Judgment entered October 20, 1997 in accordance with the Court’s order of the same date (as modified by the Judgment of the Ninth Circuit Court of Appeals dated March 23, 2000) shall represent the complete Final Judgment of this action. As the parties have by settlement waived any and all post-trial motions and rights of appeal, the date of entry of this Final Judgment shall represent the final termination of this action."

(Dated) December 16, 2002

After the conclusion of this long and costly lawsuit we at Ananda hope that there can be increasing harmony between the two organizations in the years to come. We feel that communication is most important for future understanding between the two organizations. Meanwhile, we extend our sincere love and friendship to all our gurubhais (fellow disciples) in Self-Realization Fellowship, and everywhere.



Read the online Autobiography of a Yogi

Based on the court's decision, Ananda was able to publish this book