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This article situates Hurston's largely neglected theatrical presentations of West Indian folk dance alongside the better-known dance work of Baker and Dunham in order to trace shifts in the racialized meanings surrounding black vernacular dance stagings in the early decades of the twentieth century. A comparative survey of the three artists exposes an important if complicated historical transition from stereotypical representations of black primitivity to more nuanced representations of a black diaspora.

I n 1892 Lo'ie Fuller, often figured as one of the "mothers" of modern dance, brought an infringement suit in New York against a chorus girl named Minnie Renwood Bemis in an attempt to enjoin Bemis from performing a version of the Serpentine Dance, which Fuller claimed to have invented. 1 The dance, distinctive for its use of yards of illuminated silk fabric, made the American-born Fuller famous in Europe and spawned a host of imitators on both sides of the Atlantic. Intent on staking her proprietary claim on the dance, Fuller took the precaution of submitting a written description of it to the U. S. Copyright Office. Ultimately, however, the judge for the U.S. Circuit Court denied Fuller's request for an injunction on the grounds that the Serpentine Dance told no story and was therefore not eligible for copyright protection. Although Fuller clearly regarded her expressive output as intellectual property, dance at the time lacked legal recognition as a copyrightable category in its own right and merited protection only if it qualified as a "dramatic" or "dramaticomusical composition." The precedent set by Fuller v. Bemis remained in place in the United States until the 1976 Federal Copyright Law explicitly extended protection to choreographic works. The case therefore figures prominently in historical accounts of the campaign for choreographic copyright in the United States. Typically, the court's finding that the Serpentine Dance, with its manipulations of fabric and light, was too abstract to count as dramatic is taken as evidence of Fuller's pioneering modernism. 2 Conventional wisdom holds that it was

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