Skirt dancing, involving the dancer’s graceful manipulation of a full skirt, was a widely popular genre in the U.S. when Loïe Fuller premiered her Serpentine dance in 1892.
Fuller’s costume for this dance involved so much fabric that—combined with atmospheric lighting—it almost completely obscured her human form. By shifting the focus from the dancer to the costume, she added a new level of abstraction to the skirt dance genre, prefiguring many of the innovations of modern dance.
The dance was a huge success and was much imitated, prompting Fuller to sue for copyright infringement; but the judge ruled against her, stating that a dance depicting no story, character, or emotion could not be considered a “dramatic composition” protected by the copyright act.
This according to “Loïe Fuller’s Serpentine dance: A discussion of its origins in skirt dancing and creative reconstruction” by Jody Sperling (Proceedings of the Society for Dance History Scholars XXII  pp. 53–56). Below, a hand-colored 1895 film of an unnamed dancer by the Lumière brothers suggests what Fuller’s performance was like.
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