Tatha-Nahandji v. World Wrestling Entertainment LLC — Wrestling Sequence Copyright Claim Dismissed

Background

Nathaniel Tatha-Nahandji, doing business as WCWA Wrestling, claimed that he created a recurring “Tier 1 Sequence” for a wrestling faction. The sequence combined formation, staggered arm movements, pauses, staging, and camera choices. He alleged that WWE and related video-game companies later used a similar presentation for WWE’s “Bloodline” faction.

The plaintiff registered motion pictures containing his sequence and alleged that WWE personnel could have encountered WCWA programming through a scouting tape, a live event, and publicly available Facebook and YouTube videos. He asserted direct and secondary copyright infringement, trade-dress infringement, and related state-law claims.

The Court’s Holding

The court dismissed the case with prejudice. It accepted that the registered audiovisual works could protect the original selection and arrangement of staging, movement, editing, and camera choices. But ownership alone did not plausibly establish copying.

The complaint alleged only a possibility—not a reasonable possibility—that the alleged copiers encountered the protected sequence. The scouting tape and live event predated use of the sequence, and allegations that unidentified WWE personnel may have monitored later online videos were speculative. The court also found that the accused presentations differed in timing, formation, camera angles, cueing, and overall expression. General wrestling-faction poses and gestures could not supply substantial similarity.

Because direct infringement failed, the contributory and vicarious theories also failed. The proposed amendment added no facts curing the access or similarity defects, so further amendment would have been futile.

Key Takeaways

• Online availability by itself does not plausibly establish access; a complaint needs facts connecting the work to the alleged copier.
• Copyright may protect an audiovisual sequence’s original arrangement, but not general ideas or familiar performance elements.
• Secondary infringement claims ordinarily cannot survive without plausible underlying direct infringement.

Why It Matters

The ruling shows the pleading burden facing creators who claim that a large entertainment company copied short-form staging or choreography. Registration can establish ownership, yet the claimant still must connect the work to the defendant and identify meaningful similarity in protectable expression rather than a shared concept or pose.