About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline



Case Citations [i] (Fall 2025)

handle is hein.ali/alicopyright0011 and id is 1 raw text is: 





                            THE AMERICAN


                              LAW INSTITUTE



                                     Fall 2025 Citations



                        COPYRIGHT (DRAFTS)


     CHAPTER 3.   INITIAL  OWNERSHIP, TRANSFERS, VOLUNTARY LICENSES, AND
                               TERMINATION OF GRANTS

§ 22. Joint Works

M.D.Pa.2024. Com.  (c) cit. and quot. in sup. and in ftn., Rptr's Note (d) quot. in ftn. (T.D. No. 2, 2022).
Artist filed a claim for copyright infringement against manufacturer of clothing apparel and others,
alleging that defendants used plaintiff s original dragon-themed design to assist in creating circular,
dragon-themed buttons for boots, as well as a simplified version of plaintiff s original design, without
plaintiff s authorization. This court granted in part and denied in part defendants' motion for summary
judgment, holding that there was no dispute of fact that the parties intended their contributions to the
original dragon boot button designs to be merged into an inseparable unitary whole as a joint work; in
contrast, the parties disputed as to whether plaintiff intended the original design to be merged into the
simplified design. The court noted that several persuasive commentaries, such as Restatement of
Copyright Law § 22, opposed the heightened intent standard for the requisite intent for joint
authorship in favor of a standard under which joint authors only had to share the intent to collaborate on
an indivisible unitary work. Beard v. Helman, 722 F.Supp.3d 521, 542, 550-552.
















                           COPYRIGHT C2025 By THE AMERICAN LAW INSTITUTE
                                        All rights reserved
                                  Printed in the United States of America
          For earlier citations, see the Appendices, Supplements, or Pocket Parts, if any, that correspond to the subject matter under examination.