• Francis, Day and Hunter had released a song titled “The Man Who Broke the Bank at Monte Carlo”. Years later, 20th Century Fox put out a movie by the same title, but had no other connections to the song. Francis sued for copyright infringement.
  • Held, a name alone cannot possess copyright unless it is sufficiently original and distinctive. “To break the bank” is a hackneyed expression, and Monte Carlo is or was the most obvious place at which that achievement or accident might take place.