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EFFECTS ASSOCIATES, INC. v. COHEN

No. 88-6455.

908 F.2d 555 (1990)

EFFECTS ASSOCIATES, INC., Plaintiff-counter-defendant-Appellant, v. Larry COHEN; Larco Productions, Inc.; New World Entertainment, Defendants-counter-claimants-Appellees.

United States Court of Appeals, Ninth Circuit.

Decided July 20, 1990.

Attorney(s) appearing for the Case

John Blair Overton, Sausalito, Cal., for plaintiff-counter-defendant-appellant.

Vincent Cox, Leopold, Petrich & Smith, Los Angeles, Cal., for defendants-counter-claimants-appellees.

Before CANBY, KOZINSKI and LEAVY, Circuit Judges.

KOZINSKI, Circuit Judge:

What we have here is a failure to compensate. Larry Cohen, a low-budget horror movie mogul, paid less than the agreed price for special effects footage he had commissioned from Effects Associates. Cohen then used this footage without first obtaining a written license or assignment of the copyright; Effects sued for copyright infringement. We consider whether a transfer of copyright without a written agreement, an arrangement apparently not...

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