Secured Dismissal in Copyright, Lanham Act Case Concerning Quote Used in Woody Allen Film

Secured a victory on behalf of Sony Pictures Classics Inc. when the U.S. District Court for the Northern District of Mississippi granted a motion to dismiss a complaint alleging that the use of a William Faulkner quote in the Woody Allen film Midnight in Paris violated U.S. copyright law and the Lanham Act. The court ruled that the film’s paraphrase of Faulkner’s line from the 1950 novel Requiem for a Nun was a fair use because the quote was a transformative paraphrase, repurposed for comic effect, and would have no negative impact on the market for the novel. The court also rejected the Lanham Act claim because there was no possibility that consumers would be confused as to a perceived affiliation between the late author and Sony.