Dastar Corp. v. Twentieth Century Fox Film Corp.
Headline: Ruling blocks use of trademark law to force credit for copying public-domain videos, allowing a company to sell edited World War II footage without naming earlier producers or distributors.
Holding: The Court held that ‘origin’ in the federal trademark law refers to the maker of the physical product, so the company that edited and sold the public-domain video was the origin and the trademark claim failed.
- Allows selling edited public-domain videos without mandatory credit to prior producers.
- Limits trademark law as a tool to police attribution for expired copyrights.
- Leaves copyright claims and profit-doubling issues for lower courts to decide.
Summary
Background
A book, its television series, and later videotape distributors sued a company that bought old public-domain television tapes, edited them, and sold the result as its own video set. The original book and the TV series had separate rights holders, and the TV series’ copyright had lapsed into the public domain. The sellers alleged the buyer’s packaging and credits falsely represented the videos’ origin, and they sought to recover profits and double those profits under federal trademark law (the Lanham Act).
Reasoning
The central question was what “origin” means when the law bars false statements about the origin of goods. The Court explained that the ordinary meaning of origin is the maker of the physical product offered for sale — here, the company that edited and manufactured the videotapes. Extending “origin” to the author or creator of the underlying content would overlap and conflict with copyright and patent law, which govern copying and attribution for creative works. Because the company that sold the edited tapes was the producer of the physical goods, the Court held the trademark-style claim failed. The Court reversed the lower court on that claim and did not decide whether doubling profits was permitted.
Real world impact
The decision means businesses may lawfully copy and sell public-domain audiovisual works after editing them without being forced to credit earlier creators under the Lanham Act. It does not resolve any pending copyright claims or the unresolved question about doubling profit awards, which remain for lower courts to decide.
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