US court dismisses ‘Inside Out’ copyright allegations against Disney
Copyright infringement claims brought against Disney and Pixar in relation to animated film “Inside Out” have been dismissed with leave to amend.
District Judge Philip Gutierrez delivered his findings on Wednesday, January 31, at the US District Court for the Central District of California.
Denise Daniels, a child development expert, filed an amended copyright complaint against the entertainment companies in September 2017, WIPR reported.
She alleged that the characters and concept behind the 2015 animation film “Inside Out” had been copied from her idea for a children’s TV programme called “ The Moodsters”, which centred on emotional intelligence in children.
Daniels registered “The Moodsters” bible and the pilot episode of the programme at the US Copyright Office in 2005 and 2007, respectively.
According to the claim, between 2005 and 2009, Daniels and her team held several discussions with Disney executives about developing an animated series focused on emotional intelligence in children. Pixar began work on “Inside Out” in 2010.
In December 2017, Daniels opposed Disney and Pixar’s attempt to dismiss the copyright claim, requesting that the court grant a trial. WIPR reported that Disney had offered more than 200 exhibits to support its motion for dismissal, which Daniels claimed was evidence that the case should proceed on its merits.
Gutierrez granted Disney’s motion to dismiss, finding that Daniels’ lawsuit regarding the characters from “The Moodsters” did not meet the US Court of the Appeals for the Ninth Circuit’s ‘Batmobile’ copyright test (handed down in DC Comics v Towle) which says that a character has to be physical, recognisable, and distinctive to be eligible for copyright protection.
Daniels alleged that the “The Moodsters” characters were appropriated by Disney, while Disney argued that the characters were ineligible for copyright protection, and that the characters from “Inside Out” are not “substantially similar” to Daniels’ characters.
Applying the ‘Batmobile’ test, the court found that Daniels’ characters were not deserving of copyright protection independent from the work in which they appear.
Although the characters meet the requirement of having physical as well as conceptual qualities they are not “sufficiently delineated”, meaning that the same character would not be recognised wherever it appeared.
The court dismissed Daniels’ claims and granted Daniels leave to amend the copyright infringement complaint before March 1, 2018.
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