Background
Pro se plaintiff Arias filed suit against Warner Bros. Entertainment, alleging that the studio copied his screenplay titled “Bolas de Papel” for the 2019 film Joker and its 2024 sequel Joker: Folie à Deux. Arias alleged that he submitted his screenplay through the Cannes FilmFreeway platform and that Warner Bros. subsequently used his creative work as the basis for the blockbuster films.
Arias brought four claims: (1) copyright infringement, (2) unjust enrichment, (3) conversion, and (4) a request for a permanent injunction. Warner Bros. moved to dismiss all claims.
The Court’s Holding
Copyright infringement dismissed without prejudice. Judge Altman found that Arias failed to plausibly allege either of the two key elements required for copyright infringement: access and substantial similarity. On access, the court held that submitting a screenplay to the Cannes FilmFreeway platform does not establish that Warner Bros. — a major studio with its own development pipeline — had access to or was even aware of the submission. The court found no chain of events plausibly connecting the screenplay’s submission to anyone involved in the Joker films’ development. On substantial similarity, the court found the works insufficiently similar to support an inference of copying. Arias was given until May 26, 2026 to amend this claim.
Unjust enrichment and conversion dismissed with prejudice. Both state-law claims were dismissed with prejudice as preempted by the Copyright Act. Because the claims sought recovery for the same alleged unauthorized use of a copyrighted work, they fell within the scope of rights protected by federal copyright law and could not proceed as independent state-law causes of action.
Permanent injunction claim dismissed with prejudice. The court held that a permanent injunction is a remedy, not a standalone cause of action, and dismissed this count with prejudice.
Key Takeaways
- Submitting a screenplay to a film festival platform does not, by itself, establish that a major studio had access to the work — plaintiffs must allege a plausible chain showing how the specific decision-makers could have encountered the submission.
- State-law claims like unjust enrichment and conversion are preempted by the Copyright Act when they are based on the same unauthorized copying that underlies the copyright claim.
- The court gave the plaintiff leave to amend the copyright claim, suggesting that a more detailed allegation of access could potentially survive dismissal — though the bar remains high in “screenplay copying” cases against major studios.
Why It Matters
“Studio copied my screenplay” lawsuits are a recurring genre in copyright litigation, and this ruling reaffirms the high bar plaintiffs face. Access is the critical hurdle: in an era where thousands of screenplays are submitted through online platforms, courts require more than a bare assertion that the work was “out there.” Plaintiffs must show a specific, plausible path by which their work reached the people who created the accused film. The preemption ruling also serves as a reminder that copyright provides the exclusive federal framework for protecting creative works — state-law theories that merely repackage the same copying allegation will not survive.