Brief Fact Summary. Aalmuhammed (Plaintiff) sought a declaratory judgment that he was a co-owner of the copyright in a movie and was therefore entitled to an accounting of the profits from the movie.
Synopsis of Rule of Law. A person claiming to be a co-owner of a joint work must prove that both parties intended the work to be a joint work.
Issue. Does the contribution of independently copyrightable material to a work intended to be an inseparable whole make the work a joint work?
Held. (Kleinfeld, J.)Â No.Â A joint work is one that was intended by both parties to be a joint work.Â That determination is fact specific.Â The courts will look to, among other things, the apportionment of decision-making authority and the billing accorded the various parties.Â Here, none of the parties made any objective manifestations of intent to be co-authors.Â Specifically, Plaintiff had no supervisory authority over the film and signed a â€œwork for hireâ€ agreement that prevented him from being a co-author.Â Affirmed but remanded for further proceedings on a quantum meruit claim.
The movie credits plainly and expressly repudiated authorship, by listing Aalmuhammed far below the more prominent names, as an Islamic technical consultant.View Full Point of Law