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Alameda Films S A De C V v. Authors Rights Restoration Corp.

331 F.3d 472 (2003)

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Alameda Films S A De C V v. Authors Rights Restoration Corp.

United States Court of Appeals for the Fifth Circuit

331 F.3d 472 (2003)

Facts

In the 1980s, Authors Rights Restoration Corporation, Inc.; Media Resources International, Inc.; Television International Syndicators, Inc.; and H. Jackson Shirley, III (collectively, the distributors) (defendants) distributed 88 Mexican films, of which 69 had fallen into the public domain. In 1996 the Uruguay Round Agreement Act (URAA), eliminated several formalities for authors of foreign works, including films, to copyright their works in the United States. The URAA also established automatic copyright renewal. A group of Mexican film-production companies, including Alameda Films (the studios) (plaintiffs) brought suit against the distributors, arguing that all 88 films now enjoyed renewed copyright protection. The distributors argued that only individual persons could be considered authors under Mexican law. The studios countered that a collaboration doctrine in the Mexican Civil Code gave authors’ rights to collectives. The district court found in favor of the studios. The distributors appealed. The United States Court of Appeals or the Fifth Circuit granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Wiener, J.)

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