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Video Pipeline, Inc. v. Buena Vista Home Entertainment, Inc.

United States Court of Appeals for the Third Circuit
342 F.3d 191 (2003)


Facts

Video Pipeline, Incorporated (Video Pipeline) (defendant) created videotape movie-trailer compilations for video stores to display. In creating its compilations, Video Pipe contracted with the Walt Disney Company (Disney) (plaintiff) to receive and use over 500 Disney movie trailers. When Video Pipeline began posting movie trailers online in 1997, it posted trailers for which it had acquired license agreements for videotape distribution. Disney determined that the prior license agreement did not allow Video Pipeline to use the trailers online, and Disney requested that Video Pipeline remove the trailers from its websites. Video Pipeline complied, but then filed a complaint requesting a declaratory judgment stating that it could post Disney’s trailers online under federal copyright law. In response to the action for declaratory judgment, Disney terminated the prior license. Video Pipeline then posted on its website roughly 60 two-minute clips from Disney movies as replacements for the trailers. The license agreement that Disney used to allow other websites to post its trailers online prohibited the licensee websites from criticizing Disney, its movies, or people involved in making the movies. Disney also brought a countersuit against Video Pipeline for copyright infringement. The district court granted Disney’s request for a preliminary injunction prohibiting Video Pipeline from using the clips. Video Pipeline appealed.

Rule of Law

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Issue

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Holding and Reasoning (Ambro, 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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