Bikram Yoga History: Copyright, Trademarks and the 26&2 Lineage

The history of Bikram yoga starts in Calcutta with Bishnu Ghosh, moves to Los Angeles with Bikram Choudhury in 1971, and ends up in court. A 2015 ruling found the 26&2 sequence can't be copyrighted, and USPTO records show the Bikram trademarks we checked are cancelled or abandoned. So the method now belongs to every trained teacher.

That short answer hides a long story, and most of it matters if you plan to teach.

Mr. Ian Terry, E-RYT 500 and founder of YogaFX, trained for five years, from 2014 to 2019, with the founder of the Bikram Hot 26&2 method. This guide sets his first-hand view next to the court record and the trademark files, so you can separate what is documented from what is studio folklore.

Bikram Yoga History at a Glance: Six Dates That Explain It

Bikram yoga history is easier to follow as a timeline than as a biography. Six dates carry most of the weight, and each one changed what a teacher can legally do with the sequence today.

So notice the pattern in the history of Bikram yoga. The lineage is old, the brand is from the 2000s, and the legal protection around both fell away between 2013 and 2016. That order explains why studios could rename the class without changing a single posture.

Is Bikram Yoga Copyrighted? What the 2015 Ruling Decided

No. The sequence of 26 postures and 2 breathing exercises is not protected by copyright in the United States. That is the clearest single fact in the history of Bikram yoga, and it comes from a federal appeals court, not from opinion.

The 1979 book and the copyright claim

Choudhury published Bikram's Beginning Yoga Class in 1979 and registered it for copyright that year. In 2002 he filed a supplementary registration that described the book's "compilation of exercises". His argument was simple: if the selection and order of the postures were his creative work, nobody could teach them without a licence.

Then the US Copyright Office weighed in. Three years before the court ruling, it published a policy statement (77 Fed. Reg. 37605). It said that a claim in a compilation of exercises, or in the selection and arrangement of yoga poses, will be refused registration.

What the Ninth Circuit said

On October 8, 2015, the Ninth Circuit decided Bikram's Yoga College of India, L.P. v. Evolation Yoga, LLC, 803 F.3d 1032. The court called the sequence "an idea, process, or system designed to improve health" and held that it "falls squarely within Section 102(b)'s exclusions from copyright protection." You can read the full Ninth Circuit opinion yourself.

The court also rejected the two fallback arguments. Calling the sequence a compilation didn't help, because a process doesn't become protectable when you split it into parts. Calling it choreography failed for the same reason, since functional movements stay functional whatever label they carry.

What is and isn't protected today

• Not protected: the 26 postures, the 2 breathing exercises, their order, the heat and the 90-minute format.
• Protected as text: the exact wording of a published book. Copyright covers the expression, not the idea behind it.
• Your own words: a teacher's original script or class notes belong to that teacher, the same way any written text does.

For a teacher, that means you can teach the full sequence anywhere. What you can't do is photocopy someone else's book and sell it. Our guide to the 26 postures, heat and dialogue of Bikram yoga covers the method itself in plain terms.

Is Bikram Yoga Trademarked? The USPTO Record

This is the part of the history of Bikram yoga that most articles skip, and it's the part teachers ask us about most. Copyright covers creative works. A trademark covers a brand name. So even after the 2015 ruling, the question remained: who owns the word "Bikram"?

We checked the US Patent and Trademark Office records filed in Choudhury's name. Every mark in the table below is listed as dead: either cancelled after registration or abandoned before it was ever registered.

You can open the record for the BIKRAM YOGA mark and see the cancellation entry for yourself. The two registered marks lapsed because the 10-year declaration of use was not accepted. The other five never made it onto the register at all.

What "dead" means for teachers and studios

This is a quiet turning point in the history of Bikram yoga, because a dead mark gives its former owner no registered rights in the US. That's why you'll still see "Bikram" on studio signs, and also why so many studios dropped it voluntarily. The choice was mostly about reputation, not legal risk.

• Registered rights: none of the marks above are live on the US register.
• "26 & 2": the attempt to register the numbers themselves was abandoned in 2016, so the common name of the method stays open.
• Other countries: trademark law is national. A US record says nothing about a filing in another country, so check locally before you name a studio.

This isn't legal advice. If you're about to put a name on a lease or a logo, ask a trademark lawyer in your country to run a search first.

The Early History of Bikram Yoga: Bishnu Ghosh in Calcutta

The history of Bikram yoga begins about 50 years before anyone used the word "Bikram". Bishnu Charan Ghosh was born in 1903 and was the younger brother of Paramahansa Yogananda, author of Autobiography of a Yogi. In 1923, at 20, he founded the College of Physical Education in Calcutta.

But Ghosh wasn't a guru in the devotional sense. He was a physical culturist, so he cared about measurable change in the body: strength, mobility and recovery from injury. His students used postures from the Hatha tradition as therapy and training, not as ritual.

Choudhury, born in Calcutta in 1944, later said he trained with Ghosh from early childhood. However, biographers place his regular training at Ghosh's gymnasium from about 1962, when he was 18. Ghosh died in 1970, and Choudhury left for the United States the following year.

That gap matters in the history of Bikram yoga, because the postures came from Ghosh's school. The fixed order, the heated room and the word-for-word script took shape later, in Los Angeles. So when people ask "who created Bikram yoga?", the honest answer has two names in it.

From Los Angeles to the World: 1971 to 2013

Choudhury arrived in the US in 1971 and began teaching in Los Angeles. This is the stretch of the history of Bikram yoga where the class took its modern shape:

• 26 postures and 2 breathing exercises, always in the same order.
• 90 minutes in a room heated to about 40°C with roughly 40% humidity.
• A scripted dialogue instead of demonstration or music, so any trained teacher delivers the same class.

The script is the clever part. Because the instruction is fixed, a newly certified teacher can run a complete class from day one.

So the method was easy to scale. Large teacher trainings in Los Angeles sent graduates back to dozens of countries. Mr. Ian's 12,000+ hour teaching record shows how far that one format can travel in a single career.

The brand grew alongside the method. Studios paid licence fees, the trademark filings began in 2002, and the copyright claim on the sequence followed. By the early 2010s, Choudhury's organisation was suing studios that taught the same postures under other names. The courts would soon settle that fight against him.

The Lawsuits and the Departure: 2013 to 2019

The founder's conduct is the hardest part of the history of Bikram yoga, and we won't skip it. Several former students filed civil lawsuits alleging sexual assault and harassment. Choudhury denied the allegations. One case reached a verdict, and it's the one the public record covers best.

• March 2013: Minakshi Jafa-Bodden, his head of legal and international affairs, is fired. She sues for wrongful termination and harassment.
• January 2016: a Los Angeles jury awards her 924,500 US dollars in damages, then about 6.4 million US dollars in punitive damages.
• May 2016: Choudhury returns to India and keeps teaching abroad.
• May 2017: a Los Angeles judge issues a warrant for his arrest because the judgment, by then about 7 million US dollars, remains unpaid.
• 2019: Netflix releases Bikram: Yogi, Guru, Predator, directed by Eva Orner, and many remaining studios change their names.

Some older articles, including an earlier version of this one, said the documentary came out in 2017 or that he was convicted in a criminal court. We couldn't find a record for either claim, so we've removed them. The cases above are civil judgments, and that matters when you talk to students.

For the full biography, read our profile of Bikram Choudhury, the man behind the method.

Mr. Ian Terry's View: Five Years Inside the Lineage

Mr. Ian Terry trained for five years, from 2014 to 2019, with the founder of the method. Those years run straight through the lawsuits, the departure and the documentary. So he saw both sides of the history of Bikram yoga at close range: the teaching and the culture around it.

His conclusion, which shapes how YogaFX teaches today, is that the two can be separated. The posture clinics were precise. The dialogue standard was exacting, and it produced teachers who could hold a room in their first class. Meanwhile, the deference and personality culture around the founder were things he chose not to carry forward.

In practice, that means three things in our training room:

• The method stays intact: the same 26&2 sequence, heat and dialogue structure.
• The culture changes: trainees ask questions, set their own limits and get feedback in plain language.
• The record is honest: we teach the lineage, including the parts that are uncomfortable to talk about.

Today Mr. Ian has 12,000+ teaching hours and 1,500+ graduates from 80+ countries, and he has run YogaFX since 2017. He was also confirmed in June 2026 as a Master Trainer of the Republic of Indonesia Yogasana Sports Federation.

What the Research Says About the Method That Survived

Here's the twist in Bikram yoga history: the best evidence for the method arrived after its founder's reputation collapsed. Researchers studied the class, not the man, and the results kept the practice relevant.

The most cited example is a Harvard-affiliated randomised trial of heated yoga for depression, published in the Journal of Clinical Psychiatry in 2023 (Nyer et al., PubMed 37883245). After 8 weeks, 59% of the yoga group saw their depression symptoms fall by half or more, compared with 6.3% of the waitlist group.

Earlier work points the same way. For example, a 2013 study by Tracy and Hart reported changes in strength and flexibility after a Bikram programme. A 2014 University of Wisconsin study by Porcari and colleagues measured calorie burn and heart rate in a 90-minute class. A 2025 systematic review by Willmott and colleagues pulled together 43 studies with 942 participants.

Still, none of this makes hot yoga a treatment. Research suggests it may help, but heat adds real strain, so if you have a heart condition, are pregnant or take medication, consult a healthcare professional before you start.

The 26&2 Lineage Today and Where YogaFX Fits

The history of Bikram yoga changed the name, not the class. Today the same class runs under several names: Bikram yoga, 26&2, Original Hot Yoga and Hot 26&2. The postures didn't change, so only the sign on the door did. People still search for "Bikram" far more than any new label, which we explore in why Bikram yoga is still searched so often.

Teacher training is where the history of Bikram yoga changed most. The old model was a nine-week residential course with hundreds of trainees in one room. YogaFX runs the Bikram Hot 26&2 Yoga Teacher Training MasterClass as a hybrid instead: an online pre-course for the dialogue, anatomy and history, then a 6-day intensive in Bali.

• Certification: Yoga Alliance RYT 200 plus the Bikram Hot 26&2 200-Hour International Yoga Certification.
• Next intake: check-in Sunday 24 January 2027, check-out Friday 29 January 2027, in Seminyak.
• Fee: US$1,899 Early Bird, with instalments from US$250 a month.

What graduates say about the lineage

Our trainees come for the method, and many say the lineage is part of why. Here's what three recent graduates wrote:

"This training is NOT for the faint hearted. It is for those passionate about the BIKRAM Lineage."

Anika, Google review, 2025

"I suggest this training to anyone that loves and has the respect that I have for 26 & 2. Bikram created the foundation and Mr. Ian is carrying on the lineage."

Britt, Google review, 2026

"Sharing his years of wisdom & insightful bikram teaching truly makes this Bikram 26 & 2 course an authentic & rewarding experience."

Shelley, Google review, 2026

If the history of Bikram yoga has convinced you the method is worth teaching, the next step is our 2026-2027 Bikram teacher training dates, cost and formats. It compares the 6-day hybrid with the traditional residential route.

FAQ

Is Bikram yoga copyrighted?

No. In 2015 the Ninth Circuit held that the sequence of 26 postures and 2 breathing exercises is a system or process, which copyright law excludes. The words of a published book are still protected as text, but anyone can teach the sequence itself without a licence or permission.

Is Bikram yoga trademarked?

Not on the US register. The BIKRAM YOGA mark was cancelled in 2014, and later filings for BIKRAM and 26 & 2 were abandoned. YogaFX runs an independent training, not official Bikram Choudhury Teacher Training. Trademark law is national, so check other countries separately.

What is Bikram yoga called now?

Most studios now call it 26&2, Original Hot Yoga or Hot 26&2, while some still use Bikram. The class is the same under every name: 26 postures, 2 breathing exercises and 90 minutes in a room of about 40°C. Only the branding changed after the founder's legal troubles.

When was Bikram yoga created?

The history of Bikram yoga starts at Bishnu Ghosh's Calcutta school, founded in 1923. Bikram Choudhury shaped those postures into the fixed 26&2 sequence, heated room and scripted dialogue after he began teaching in Los Angeles in 1971. His book describing the class was published and registered in 1979.

Did Bikram invent hot yoga?

He made heat a fixed part of a yoga class and turned it into a global format, so most hot yoga styles trace back to his studios. He didn't invent the postures, though. Those came from Bishnu Ghosh's school in Calcutta, where the warm climate was simply part of practice.

Still have questions about the lineage or the training? Message Mr. Ian and the YogaFX team on WhatsApp and we will answer you personally.