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Keywords

copyrightcorporation
copyrightcorporationrespondent

Related Cases

Dastar Corp. v. Twentieth Century Fox Film Corp., 539 U.S. 23, 123 S.Ct. 2041, 156 L.Ed.2d 18, 194 A.L.R. Fed. 731, 71 USLW 4415, 2003 Copr.L.Dec. P 28,622, 66 U.S.P.Q.2d 1641, 03 Cal. Daily Op. Serv. 4554, 2003 Daily Journal D.A.R. 5799, 16 Fla. L. Weekly Fed. S 330
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Zyla v. Wadsworth, Div. of Thomson Corp., 360 F.3d 243, 2004 Copr.L.Dec. P 28,757, 69 U.S.P.Q.2d 1915
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Tire Engineering and Distribution, LLC v. Shandong Linglong Rubber Co., Ltd., 682 F.3d 292, 2012 Copr.L.Dec. P 30,263, 103 U.S.P.Q.2d 1183
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Tire Engineering and Distribution, LLC v. Shandong Linglong Rubber Co., Ltd., 682 F.3d 292, 2012 Copr.L.Dec. P 30,263, 103 U.S.P.Q.2d 1183
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Twentieth Century Fox Film Corp. v. Dastar Corp., Not Reported in F.Supp.2d, 2000 WL 35503105
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Dastar Corp. v. Twentieth Century Fox Film Corp., 539 U.S. 23, 123 S.Ct. 2041, 156 L.Ed.2d 18, 194 A.L.R. Fed. 731, 71 USLW 4415, 2003 Copr.L.Dec. P 28,622, 66 U.S.P.Q.2d 1641, 03 Cal. Daily Op. Serv. 4554, 2003 Daily Journal D.A.R. 5799, 16 Fla. L. Weekly Fed. S 330

Facts

Dastar Corp. produced a video set titled 'World War II Campaigns in Europe' using material from the public domain television series 'Crusade in Europe,' which had originally been produced by Twentieth Century Fox Film Corporation (Fox). Fox had exclusive rights to the series until the copyright expired in 1977, leaving it in the public domain. Dastar marketed its video set without attribution to Fox, leading Fox and its affiliates to sue Dastar for reverse passing off under the Lanham Act. The District Court ruled in favor of Fox, but the Supreme Court ultimately reversed this decision.

General Dwight D. Eisenhower's World War II book, Crusade in Europe, was published by Doubleday, which registered the work's copyright and granted exclusive television rights to an affiliate of respondent Twentieth Century Fox Film Corporation (Fox). Fox, in turn, arranged for Time, Inc., to produce a Crusade in Europe television series based on the book, and Time assigned its copyright in the series to Fox.

Issue

Rule

Analysis

In this case, Dastar was deemed the 'origin' of the physical videotapes it sold, as it produced and marketed them as its own. The court reasoned that the Lanham Act's language does not cover the original creators of the content embodied in the goods, especially when those works are in the public domain. Thus, Dastar's actions did not constitute reverse passing off under the Act, as it did not misrepresent the origin of the physical goods it sold.

Conclusion

The Supreme Court held that the Lanham Act does not prevent the unaccredited copying of an uncopyrighted work, reversing the lower court's ruling.

Held: Section 43(a) of the Lanham Act does not prevent the unaccredited copying of an uncopyrighted work.

Who won?

Dastar Corp. prevailed in this case because the Supreme Court found that it was the 'origin' of the physical products it sold, and that the Lanham Act does not extend to protect against the unaccredited copying of works that are in the public domain. The Court emphasized that the Act's purpose is to prevent consumer confusion regarding the source of goods, not to protect the original creators of ideas or content once their copyright has expired.

Dastar was the origin of the physical products it sold as its own, and thus, the respondents cannot prevail on their Lanham Act claim.

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