On August 3, the United States Court of Appeals for the Ninth Circuit, in Masterson v. Walt Disney Company, affirmed a district court’s dismissal of Carla Masterson’s copyright infringement claims against The Walt Disney Co. The infringement claim was based on Masterson’s allegation that Disney’s Inside Out (the Movie) violated her copyrights in her book of poetry, What’s On the Other Side of the Rainbow? (A Book of Feelings) (the Book) and her movie script, The Secret of the Golden Mirror (the Script). Masterson’s Book was a collection of poems featuring a cloud-like character, Mr. Positivity, and anthropomorphic doors representing different feelings. The Script is about Mr. Positivity and the anthropomorphic doors helping a child cope with a difficult situation. In contrast, Disney’s Inside Out is about an eleven-year-old girl and the anthropomorphized emotions that control her brain from her brain’s “Headquarters.” The district court held that the literary works were not substantially similar and granted Walt Disney’s motion to dismiss.
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