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Miramax Films Corp. v. Columbia Pictures Entertainment
United States District Court for the Southern District of New York
996 F. Supp. 294 (1998)
Columbia Pictures Entertainment, Inc. (Columbia) (defendant) and Mandalay Entertainment, Inc. (Mandalay) (defendant) produced and distributed the slasher film I Know What You Did Last Summer. The film’s radio, television, and print advertising heavily emphasized the film’s origin as being “from the creator of Scream,” a similarly themed and highly successful movie from the previous year. Miramax Films Corporation (Miramax) (plaintiff), the distributor of Scream, brought suit for unfair competition under common law and the Lanham Act. Miramax alleged that the advertising campaign was intended to imply the involvement of Scream director Wes Craven in I Know What You Did Last Summer. However, the only creative link between the two films was a relatively unknown screenwriter, Kevin Williamson. Miramax presented the results of two surveys in which a significant number of moviegoers were under the impression that I Know What You Did Last Summer was a sequel to Scream or was directed by Craven, while no more than 2 percent understood the advertising campaign to refer to Williamson. Miramax moved for a preliminary injunction against Columbia and Mandalay’s advertising campaign.
Rule of Law
Holding and Reasoning (Cedarbaum, J.)
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