Dastar Corp. v. Twentieth Century Fox Film Corp.

539 U.S. 23 (2003) Supreme Court of the United States 2003-06-02

Review of summary judgment imposing reverse-passing-off liability; judgment reversed and remanded, with copyright issue separately unresolved. (result: claimant-lost)

Facts

  1. 4 Misleading affiliation approval or sponsorship not law
    To make Campaigns, Dastar purchased eight beta cam tapes of the original version of the Crusade television series, which is in the public domain, copied them, and then edited the series.
  2. 4 Misleading affiliation approval or sponsorship not law
    Dastar manufactured and sold the Campaigns video set as its own product.
  3. 4 Misleading affiliation approval or sponsorship not law
    In sum, reading the phrase “origin of goods” in the Lan-ham Act in accordance with the Act’s common-law foundations (which were not designed to protect originality or creativity), and in light of the copyright and patent laws (which were), we conclude that the phrase refers to the producer of the tangible goods that are offered for sale, and not to the author of any idea, concept, or communication embodied in those goods.
  4. 4 Misleading affiliation approval or sponsorship not law
    Because we conclude that Dastar was the “origin” of the products it sold as its own, respondents cannot prevail on their Lanham Act claim.