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Seiler v. Lucasfilm, Ltd.

797 F.2d 1504 (1986)

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Seiler v. Lucasfilm, Ltd.

United States Court of Appeals for the Ninth Circuit

797 F.2d 1504 (1986)

Facts

Lee Seiler (plaintiff) was a graphic artist. Seiler sued Lucasfilm, Ltd. (defendant) for copyright infringement, asserting that the Imperial Walkers that appeared in the company’s film The Empire Strikes Back were copied from drawings that Seiler had made in 1976 and 1977. The Empire Strikes Back came out in 1980. Seiler did not obtain a copyright for his drawings until 1981 and did so by using reconstructions of his original drawings. At trial, Seiler sought to introduce these reconstructions into evidence. Seiler did not have the originals of his drawings. At an evidentiary hearing on the admissibility of the drawings, the district court ruled that the reconstructions were not admissible under the best-evidence rule. The court found that the unavailability of the original drawings was due to Seiler’s bad faith. As a result of this ruling, the court granted Lucasfilm summary judgment. Seiler appealed.

Rule of Law

Issue

Holding and Reasoning (Farris, J.)

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