In a non-precedential ruling by summary order, the US Court of Appeals for the Second Circuit affirmed the dismissal of a copyright infringement lawsuit filed against famed comedian Jerry Seinfeld, finding that the defendant’s claims, which accrued in 2012, were time-barred. Christian Charles v. Jerry Seinfeld, et al., Case No. 19-3335 (2d Cir. May 7, 2020) (Summary Order).
In 2011, Christian Charles and his production company helped develop the pilot episode of Seinfeld’s television series Comedians in Cars Getting Coffee. In early 2012, Charles requested backend compensation from Seinfeld, alleging authorship and ownership in the show. Seinfeld immediately rejected his request, asserting that Charles’s work as a producer and director on the pilot was limited to a work-for-hire basis. When the show premiered in July 2012, Charles was not credited.
More than six years later, Charles sued Seinfeld for copyright infringement based on his claimed authorship in the series. The district court granted the Seinfeld show’s motion to dismiss on the ground that Charles’s copyright infringement claims were time-barred. Charles appealed.
The Second Circuit affirmed, agreeing with the district court’s framing of the dispositive issue in the case being whether Charles’s alleged contributions to the television series qualified him as an author and owner of copyrights to the show. Having defined the issue, the Court explained that a claim under the Copyright Act must be brought “within three years after the claim [has] accrued,” and cited precedent confirming that a copyright ownership claim accrues only once at the time a “reasonably diligent plaintiff would have discovered that ownership was disputed.” Furthermore, the Court explained that when ownership is the dispositive issue in an infringement case and the ownership claim is time-barred under the three-year rule, the infringement claim itself is also time-barred.
Given the facts of the case, the Second Circuit cosigned the district court’s “well-reasoned opinion,” finding that either of the events in 2012, namely, Seinfeld’s rejection of Charles’s request for backend compensation or the public repudiation of ownership, given that the show did not credit Charles, were enough to place Charles on notice that his ownership claim was disputed. Therefore, his lawsuit filed six years later was time-barred.