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Adjmi v. DLT Entertainment Ltd.

Citations: 97 F. Supp. 3d 512; 114 U.S.P.Q. 2d (BNA) 1784; 2015 U.S. Dist. LEXIS 43285; 2015 WL 1499575Docket: No. 14 Civ. 568(LAP)

Court: District Court, S.D. New York; March 31, 2015; Federal District Court

Narrative Opinion Summary

In this legal dispute, the plaintiff sought a declaratory judgment to establish that his play, *SC*, did not infringe upon the copyright of the television series *Three’s Company*, owned by DLT Entertainment LTD (DLT). After receiving a cease-and-desist letter from DLT, the plaintiff moved for judgment on the pleadings, which the court granted. The central legal issue revolved around whether the plaintiff's use of thematic and character elements from *Three’s Company* in *SC* constituted fair use under copyright law. The court employed a comparative analysis of the original series and the play, focusing on the transformative nature of *SC* as a parody, which altered the original's comedic elements into a darker narrative. Examining the statutory fair use factors, the court emphasized the play's transformative character and lack of market substitution for the original series. Ultimately, the court ruled in favor of the plaintiff, affirming that *SC* constituted a fair use parody, and allowed the judgment for the plaintiff on the pleadings. The decision underscored the balance between promoting creative expression and protecting original works under copyright law.

Legal Issues Addressed

Declaratory Judgment Action

Application: Adjmi sought a declaratory judgment that his play *SC* does not infringe upon DLT's copyright of *Three’s Company*.

Reasoning: Adjmi filed a Complaint on January 30, 2014, seeking a declaration that *SC* does not infringe DLT’s copyright.

Factors for Determining Fair Use

Application: The court analyzed the four factors of fair use, focusing on the purpose, character, and transformative nature of *SC* compared to *Three’s Company*.

Reasoning: The commercial nature of SC weighs against a fair use finding; however, the character and purpose analysis suggests otherwise.

Fair Use Doctrine under Copyright Law

Application: The court determined that Adjmi's play *SC* is a transformative parody of *Three’s Company* and qualifies as fair use, despite DLT’s ownership of the copyright.

Reasoning: The court determined that Adjmi's screenplay constitutes a parody and qualifies as fair use, despite acknowledging DLT's ownership of the copyright in 'Three's Company' and that elements of the original were copied.

Market Impact in Fair Use Analysis

Application: The court found that *SC* did not serve as a market substitute for *Three’s Company*, thus not causing actionable harm under copyright law.

Reasoning: The Court examined SC alongside Three’s Company and contemporary reviews, concluding that SC does not serve as a market substitute for the original series, indicating no actionable harm under the Copyright Act.

Motion for Judgment on the Pleadings

Application: The court granted Adjmi's motion for judgment on the pleadings, requiring that all allegations be treated as true while resolving inconsistencies in favor of DLT.

Reasoning: Adjmi subsequently moved for judgment on the pleadings and a stay of discovery, both of which were granted by the court.