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E-Alert Case Updates

Everything You Need to Know About The Indigo Book

(May 2016)
by Caroline E. Willsey, Law Clerk
Semmes, Bowen & Semmes (

Available at:

Last month The Indigo Book: An Open and Compatible Implementation of A Uniform System of Citation was released. The Indigo Book is a free version of the uniform system of citation implemented by the more widely-known Bluebook. The Indigo Book was inspired by Frank Bennett, a law professor at Nagoya University in Japan. In 2011, Bennett was working to add features that could support legal writing to Zotero, a software system designed to help researchers “organize, cite and share research sources.” Not long after his work began, Bennett received “keep off the grass” warnings from the Harvard Law Review Association (HLRA), which publishes The Bluebook.

Bennett’s work was picked up by Public.Resource.Org’s founder Carl Malamud and New York University law professor Christopher Jon Sprigman. In support of a free version of the uniform system of citation, Sprigman has argued that The Bluebooks system of citation is effectively in the public domain already because the copyright has lapsed – due to non-renewal – on the 10th edition of The Bluebook (published in 1958). The current 20th edition of The Bluebook is nearly identical in substance to the public domain 10th edition. Moreover, use of The Bluebook’s uniform system of citation is mandated by courts around the country. According to Sprigman, this makes The Bluebook’s system of citation an “edict of government,” which Sprigman believes should be made widely available at no cost.

In October 2014, Malamud announced his plan to publish a free version of the Bluebook’ssystem of citation, known as Baby Blue. In December 2015 – just prior to the scheduled release of Baby Blue – the HLRA threatened legal action against Malamud and Sprigman’s project. The HLRA argued that Baby Blue violated HLRA’s copyright rights in The Bluebook as well as HLRA’s “Bluebook” trademark. Sprigman fought back hard against the copyright violation allegations. According to Sprigman, “systems” – like The Bluebook’s uniform system of citation – are unprotected by copyright, under Section 102(b) of the Copyright Act. In response to the trademark concerns, Malamud and Sprigman changed the name of their guide to The Indigo Book on March 31, 2016. The Indigo Book was released via Public.Resource.Org in April 2016.

The Indigo Book serves as an unofficial substitute to The Bluebook. While The Indigo Book is not the same as the Bluebook, it does implement the same uniform system of citation. Anyone using The Indigo Book will create an identical citation to someone using The Bluebook. The scope of The Indigo Book is roughly equivalent to The Bluebook’s “Bluepages.” The Indigo Book provides legal citation guidance for all U.S. legal materials, books, periodicals, Internet and other electronic resources. The Indigo Book also provides more in-depth guidance on how to cite bills and legislative history. Where The Indigo Book does not provide guidance, it has done so intentionally. The Indigo Book’s scope excludes looseleaf reporters, foreign legal materials and publications of international organizations. Sprigman justified the exclusion of these types of sources, saying “[m]ost American lawyers cite these materials only rarely, and providing citation rules for the enormous number of international jurisdictions is part of what makes The Bluebook as unwieldy as it has become.”

Unlike The Bluebook, The Indigo Book is provided to the public free of charge. Spigman and Malamud believe that given how important the uniform system of legal citation has become in the American justice system, it is vital that “pro se litigants, prisoners, and others seeking justice but who lack resources are given effective access to the system lawyers use to cite to the law.” The Indigo Book is also free from copyright restrictions. Spigman and Malamud’s hope is that The Indigo Book’s users will copy, distribute, and improve upon their original work.

It is important to remember that The Indigo Book has not replaced The Bluebook. Rather, it is merely an alternative source of the uniform system of legal citation. The Bluebook is still published by the HLRA and can be purchased in print or online.