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Lindsay v. Wrecked & Abandoned Vessel R.M.S. Titanic

United States District Court for the Southern District of New York
52 U.S.P.Q. 2d 1609 (1999)


Lindsay (plaintiff) contracted with a television company to direct and film a documentary about the salvage of the RMS Titanic. The film followed RMST’s (defendant) third salvage expedition of the ship, during which Lindsay spent a month filming the wreck. Lindsay planned a later film project involving the Titanic wreck site based on his experience filming the documentary. He decided to film the wreck using high-illumination lighting equipment mounted on custom-designed lighting towers installed at specific locations underwater around the site. Lindsay spent several weeks directing creation and placement of the lighting towers, detailing shot angles, and deciding on equipment to be used for the shoot. However, Lindsay’s instructions were carried out by others, and Lindsay did not capture the footage himself. RMST eventually licensed the footage to the Discovery Channel, and Lindsay filed suit for copyright infringement. RMST filed a motion to dismiss.

Rule of Law


Holding and Reasoning (Baer, J.)

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