Narrative Opinion Summary
This case involves a seven-count lawsuit filed by several plaintiffs against multiple defendants, including a video game manufacturer and distributors, alleging infringement of rights related to the plaintiffs’ likenesses and performances in the Mortal Kombat games. Claims included violations of the right of publicity, the Copyright Act, and a quantum meruit claim. The court granted summary judgment for the defendants, determining that the plaintiffs' right of publicity claims were preempted by the Copyright Act, as their performances were considered fixed, original works within the copyright subject matter. The court further found that the plaintiffs' contributions were works for hire, granting the defendants sole copyright ownership. The plaintiffs failed to demonstrate joint authorship, as they could not provide evidence of intent to be joint authors. Additionally, the quantum meruit claim was dismissed due to the existence of a valid contract. Ultimately, the court ruled in favor of the defendants on all counts, as the plaintiffs did not establish any genuine issue of material fact to contest the defendants' motion for summary judgment.
Legal Issues Addressed
Joint Authorship in Copyrightsubscribe to see similar legal issues
Application: The plaintiffs were not considered joint authors of the copyrighted source codes as they failed to provide evidence of intent to be joint authors with Midway.
Reasoning: Plaintiffs fail to provide evidence countering Midway’s claim that they were not considered collaborators or joint authors.
Quantum Meruit in Presence of Valid Contractsubscribe to see similar legal issues
Application: The quantum meruit claim was dismissed because an enforceable contract existed, evidenced by the signed General Release.
Reasoning: Under Illinois law, such a claim is not viable when an enforceable contract exists between the parties. The plaintiffs’ quantum meruit claim failed as they had a valid agreement, evidenced by the signed General Release.
Right of Publicity and Copyright Preemptionsubscribe to see similar legal issues
Application: The plaintiffs' right of publicity claims are preempted by the Copyright Act as the videotaped performances meet the fixation requirement and fall within the copyright subject matter.
Reasoning: Plaintiffs' videotaped choreographic works also meet the fixation requirement and are considered original works that fall under copyright. Applying the Section 106 test, the right of publicity infringed by distribution or performance aligns with rights in Section 106, leading to the conclusion that the plaintiffs' claim is preempted.
Summary Judgment Standardsubscribe to see similar legal issues
Application: The court granted summary judgment to the defendants as the plaintiffs failed to demonstrate any genuine issue of material fact regarding their claims.
Reasoning: The summary judgment procedure requires that if the moving party shows no genuine issue of material fact, judgment should be granted.
Works for Hire and Copyright Ownershipsubscribe to see similar legal issues
Application: The court ruled that plaintiffs' contributions were works for hire, granting Midway sole ownership of the copyrightable expressions related to the games.
Reasoning: A general release signed by the plaintiffs designated Midway as the exclusive owner of all copyrightable expressions related to the arcade games and confirmed that the plaintiffs’ contributions were classified as 'works for hire.'