Seventh Circuit: "Go Pack Go" and Other Fan Chants Are Too Short to Copyright
Photo: alessandra1barbieri / Pixabay
Short slogans do not become protected works because they appear in a song. The federal appeals court in Chicago (Seventh Circuit) applied that rule on 28 October 2026 in McMillan v National Football League, upholding the dismissal of a songwriter's copyright suit.
Calvin McMillan wrote songs about the Green Bay Packers with titles and lyrics including "Pack Attack" and "Go Pack Go". He sued in the federal court for the Eastern District of Wisconsin against the league and the state's revenue department, claiming that Wisconsin lottery tickets carrying the Packers' name used his words. The tickets were printed under a licence between the league and the state agency. The district court screened the complaint and dismissed it for failure to state a claim.
The appeals court affirmed in a short nonprecedential order. It found that McMillan had not shown he held a registered copyright in the songs, a precondition for suing over a US work. Even setting that aside, the panel said, fan phrases like "Go Pack Go" and "Pack is Back" are short, common expressions that lack the originality copyright requires, even when read as song lyrics.
Why it matters. Courts in many countries refuse copyright for names, titles and short phrases, which are better protected, if at all, as trade marks. Sports clubs and leagues usually register their chants and slogans as marks for that reason.
Indonesian angle. Indonesia's Copyright Law likewise excludes ideas and very short expressions without originality, and many Indonesian football supporters' chants are shared freely. Songwriters who want to claim rights in a catchy line should look to trade mark registration at DJKI for merchandise, and record the full song with DJKI's copyright registration to help prove authorship.
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