Mandeville-Anthony v. Walt Disney Co.

Mandeville-Anthony v. The Walt Disney Company, 11-56441 (9th Cir. 2012), is a United States Court of Appeals for the Ninth Circuit case in which the Court evaluated whether defendants Pixar, The Walt Disney Company, Disney Enterprises, Inc. and Walt Disney Pictures infringed on Jake Mandeville-Anthony's copyrighted works. Plaintiff Mandeville-Anthony's claim for copyright infringement was first dismissed by the United States District Court for the Central District of California, because the court found that the parties' works were not substantially similar.[1] Mandeville-Anthony made copyright infringement claims with regards to his works Cookie & Co. and Cars/Auto-Excess/Cars Chaos, an animated television show and movie, that he believed Disney copied in order to make their own films, Cars and Cars 2, both of which were very successful, and the animated television show Cars Toons: Mater's Tall Tales. He also made breach of contract claims stating that he and Disney signed a contract barring Disney from using the ideas contained in his works. The decision was affirmed by the Court of Appeals.

History

In June 2006, Disney released Cars, based on a story about an anthropomorphic racing car whose journey transforms him from an arrogant hotshot into someone who has learned the true meaning of love, friendship, family and life.

District Court opinion

The United States District Court, C.D. Cal. held that The Walt Disney Company showed that the protectable elements of the film such as plot, sequence of events, pace characters, theme, mood and setting were not substantially similar to Mandeville-Anthony's works as a matter of law.[6] Rather, the Court held that the plots of the parties' works were wildly different.[5]

With respect to the parties' main characters, the plaintiff's two-dimensional cars contained human-like appendages, eyes as headlights, eyelashes, and were black and white, while the defendant's cars were complex, three-dimensional and full color, computer-animated characters. The examples used were the plaintiff's Manny Morris character and the defendant's Mater character. The only similarity the court found between Cars and Cookie was the unprotectable concept of car racing, and between Cars and Cars Chaos was the generic idea of anthropomorphic cars, animated car characters with human characteristics.[5] The court also held that Disney showed sufficient evidence that the statute of limitations had expired, as Mandeville-Anthony filed his complaint five years after Cars was released.

Circuit Court opinion

The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision that there was no substantial similarity between the plaintiff's protected elements of copyrighted works and the defendant's works as a matter of law. It also cited Benay v. Warner Bros. Entm’t, Inc., 607 F.3d 620, 624 (9th Cir. 2010) and stated that general concepts such as car racing and anthropomorphic cars are unprotected by copyright. Lastly, it stated that district court properly granted judgment on Jake Mandeville-Anthony's state law claim for breach of implied contract because it was barred by the applicable two-year statute of limitations, and neither delayed discovery nor a continuing violations theory applied to extend the limitations period.[7] The Ninth Circuit believed overall that Mandeville-Anthony's arguments were unpersuasive.

court	United States Court of Appeals for the Ninth Circuit
date decided	July 17, 2012
full name	Mandeville-Anthony v. The Walt Disney Company
citations	11-56441; D.C. No. 2:11-cv-02137-VBF-JEM
judges	Mary M. Schroeder, Sidney Runyan Thomas, Barry G. Silverman
opinions	The appellate court affirmed the district court's opinion that The Walt Disney Company's films Cars, Cars 2, and Cars Toons do not infringe on copyrighted works of Jake Mandeville-Anthony because they are not substantially similar as a matter of law.

Mandeville-Anthony v. Walt Disney Co.

History

Trial Court proceedings

Defendant's claims

Plaintiff's claims

District Court opinion

Circuit Court opinion

See also

External links

References