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Forest Park Pictures v. Universal Television Network, Inc.

United States Court of Appeals for the Second Circuit

683 F.3d 424 (2012)

Facts

Forest Park Pictures (Forest Park) (plaintiff) developed an idea for a television series. The series was based on a fictional doctor who, after losing his license, became a concierge doctor to the rich and famous. Forest Park submitted its idea to USA Network, a division of Universal Television Network, Inc. (Universal) (defendant). In what is referred to as a series treatment, Forest Park developed character biographies, themes, and storylines for the potential show. Forest Park met with Universal executives to discuss moving forward with the show. However, communications eventually ceased with no actual contract being executed between the parties. Four years later, USA Network aired a television show with a very similar plot to the one pitched by Forest Park. Forest Park filed a diversity action in federal court for breach of implied contract. Universal moved to dismiss the complaint, claiming that the Copyright Act preempted the breach-of-contract claim and that the alleged contract was too vague to enforce. The district court dismissed the case on the preemption claim alone, declining to address the vagueness argument. Forest Park appealed.

Rule of Law

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Issue

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Holding and Reasoning (Walker, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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