Definition
In law, "chart" has carried a specific technical meaning distinct from its broader popular usage, particularly in the context of copyright law. As used in the Copyright Act of 1790 and interpreted by courts through the nineteenth century, a chart meant a marine or hydrographic map — a navigational document depicting portions of ocean, waterways, coastlines, or other bodies of water, intended for use by seamen. This narrow meaning excluded tabulated data, statistical displays, or other graphically organized information sheets, even if labeled "charts" in common speech.
The legal significance of the definition arose chiefly when courts had to determine what works qualified for copyright protection under statutory language that listed "maps, charts, and books." Whether a particular document — say, a table of railroad schedules or a sheet of methodically arranged figures — constituted a protectable "chart" turned on how narrowly or broadly the word was read.
Common Language
Modern common usage (Wiktionary): To draw a chart or map; to figure out a route or plan; to record information systematically; to enter information into a medical record; to appear on a hit-recording chart.
Historical common usage (Webster's 1913): A sheet of paper or pasteboard on which information is exhibited, especially in tabular form; a map, especially a hydrographic or marine map intended for seamen.
The gap matters. By 1913, Webster's had fully absorbed the broader popular meaning — any tabular or graphically organized sheet of paper. But courts interpreting the Copyright Act of 1790 refused to import that expanded meaning retroactively, holding that "chart" meant only what it meant when the statute was enacted: a marine map. The Webster's 1913 definition reflects the popular usage that courts explicitly rejected as a basis for copyright protection.
Common Confusion
The term is easily confused with "map" and "table" in copyright contexts. A chart in the legal sense is a species of map — specifically a nautical one — not a synonym for any visual data display. Researchers encountering nineteenth-century copyright disputes should not assume that a document described as a "chart" in the colloquial sense (a statistical table, a genealogical chart, an organizational diagram) would have been treated as a "chart" under copyright law. The reverse error also occurs: assuming that because marine charts were clearly protected, all graphically organized information enjoyed equivalent protection. Courts drew the line precisely at the marine-map definition.
Why It Matters in Research
The research significance of this term is almost entirely historical and jurisdictional to nineteenth-century U.S. copyright law. Several points warrant attention:
First, the statutory context is narrow. The word "chart" appears in the Copyright Act of 1790 alongside "map" and "book." Courts construing that language gave "chart" its 1790 meaning, not its later popular meaning. Researchers working with copyright cases from roughly 1790 through the late nineteenth century must apply this period-specific reading rather than importing modern or even contemporaneous dictionary definitions.
Second, the dictionary inflection point is documented. Anderson's entry precisely identifies when the broader definition entered major American dictionaries: Worcester's in 1864, Webster's in 1865. This creates a before/after line in lexicographic history that directly affected legal arguments. A party litigating a copyright claim in 1870 could point to Webster's — but courts remained skeptical, anchoring interpretation to 1790 usage.
Third, the Taylor v. Gilman decision (24 Fed. 632) is the anchor case. Both editions of Black's cite it, making it the standard reference for the legal meaning of "chart" in copyright. Researchers should locate and read that decision when tracing any nineteenth-century copyright dispute involving the word.
Fourth, modern copyright law has resolved the substantive question differently. Current U.S. copyright law protects a broad range of pictorial, graphic, and audiovisual works, and the old statutory enumeration has been replaced by a more comprehensive framework. The historical "chart means marine map" rule is a dead letter for contemporary practice but remains essential for understanding historical copyright litigation.
Historical Dictionary Support
All three source dictionaries converge on the same proposition: "chart" in copyright law does not include sheets exhibiting tabulated or methodically arranged information. Black's (1st Ed.) and Black's (2nd Ed.) state this identically, differing only in that the second edition adds the Taylor v. Gilman citation explicitly. Anderson's provides the most historically detailed treatment, tracing the word to its use in the Copyright Act of 1790 and documenting the lexicographic expansion in the 1860s.
Anderson's entry is the most useful for researchers because it explains the mechanism of the interpretive dispute — not merely what the courts held, but why the historical meaning controlled over contemporary dictionary usage. The entry appears to be cut off mid-sentence ("The word, in the p—"), suggesting the original text continued with further discussion that was not captured.
None of the historical sources address how "chart" functions in other legal contexts (maritime navigation law, admiralty, surveying, or medical records), because those usages did not generate the same definitional litigation. Researchers should not assume the copyright-specific definition governs all legal uses of the word.
Jurisdictional Note
The narrow "marine map" definition arose under federal copyright law and was applied by federal circuit courts. State law uses of the term were not subject to the same definitional constraint. In admiralty and maritime contexts, the marine-map meaning was simply assumed rather than litigated, because no definitional dispute arose there.