Shapiro Arato Bach Wins Summary Judgment Dismissing All Claims Against TV Show Creator In Copyright Dispute
On December 7, 2023, the Honorable Stephen V. Wilson of the United States District Court for the Central District of California ruled in favor of Shapiro Arato Bach client Katori Hall, dismissing claims that her widely acclaimed television show, P-Valley, infringed on another playwright’s works.
Ms. Hall, an award-winning playwright, based P-Valley on her earlier stage play, which she developed after extensive research, and which involved the same setting, characters, and themes. Nevertheless, the plaintiff alleged that either Ms. Hall or the television studios that produced P-Valley had impermissibly copied the plaintiff’s play, Soul Kittens Cabaret. After an exhaustive review of P-Valley and the plaintiff’s play, however, Judge Wilson granted summary judgment dismissing all of the plaintiff’s claims. The Court held “no reasonable jury” could find the two works to be substantially similar, a necessary predicate for a copyright infringement claim. Although both works focused on female dancers working in adult entertainment, their expression of this idea “takes on very different forms.” Moreover, the court observed the plaintiff’s descriptions of both works were “plagued with mischaracterizations” that were sometimes “blatant.” The court held there were “very significant differences in the way that the works make use of unprotectible elements” and it also found that their protectible elements meaningfully diverged. Consequently, the court granted summary judgment in favor of Ms. Hall and the studios that produced her work.
The Shapiro Arato Bach team representing Ms. Hall included Cynthia S. Arato and Alice Buttrick. The court’s opinion can be found here.