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Zito v. Steeplechase Films

267 F. Supp. 2d. 1022 (2003)

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Zito v. Steeplechase Films

United States District Court for the Northern District of California
267 F. Supp. 2d. 1022 (2003)

Facts

Tom Zito (plaintiff) took a photograph of Ansel Adams in front of Half Dome in Yosemite National Park, and Zito owned the copyright in the photograph. Steeplechase Films (Steeplechase) (defendant) used the photograph in a documentary film about Ansel Adams without giving artistic credit to Zito. Zito sued Steeplechase in federal district court for reverse passing off and other claims. The reverse-passing-off claim alleged that Steeplechase had violated Zito’s rights under § 43(a) of the federal Lanham Act by failing to give Zito artistic credit for the photograph. Steeplechase moved to dismiss the claim, arguing that it was not a valid claim as a matter of law. The district court considered the motion.

Rule of Law

Issue

Holding and Reasoning (Whyte, J.)

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