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Wendt V Host Essay Research Paper US (стр. 2 из 4)

subject to the less demanding commercial speech standard of

Central Hudson Gas & Elec. Corp. v. Public Serv. Comm.,

447 U.S. 557, 561-63 (1980). Here, the portrayal of the

Cheers characters is core protected speech: Using Norm and

Cliff dummies in a Cheers-themed bar is a dramatic presenta-

tion.8 It’s like a play. Cheers may not have the social impact

of Hair, see Southeastern Promotions, Ltd. v. Conrad, 420

U.S. 546 (1975), but it’s a literary work nonetheless, worthy

of the highest First Amendment protection from intrusive

state laws like California’s right-of-publicity statute. See

Cardtoons, L.C. v. Major League Baseball Players Ass’n, 95

F.3d 959, 970-72 (10th Cir. 1996). Host did not plaster

Wendt’s face on a billboard with a Budweiser logo. It cashed

in on the Cheers goodwill by creatively putting its familiar

mise-en-scene to work. The robots are a new derivation of a

copyrighted work, not unlike a TV series based on a movie or

_________________________________________________________________

8 No doubt the decision to put animatronic Norm and Cliff figures in the

bars was profit-driven. But that doesn’t mean Central Hudson applies: The

Supreme Court limits the outhouse of commercial speech to pure

advertising–speech that does no more than propose a commercial trans-

action. Virginia State Bd. of Pharmacy v. Virginia Citizens Consumer

Council, Inc., 425 U.S. 748, 762 (1976); Nordyke v. Santa Clara County,

110 F.3d 707, 710 (9th Cir. 1997); Cardtoons, L.C. v. Major League Base-

ball Players Ass’n, 95 F.3d 959, 970 (10th Cir. 1996).

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a Broadway play based on a novel. The novelty of using ani-

matronic figures based on TV characters ought to prick up our

ears to First Amendment concerns. Instead we again let the

right of publicity snuff out creativity.

VI

As I noted in White, “No California statute, no California

court has actually tried to reach this far. It is ironic that it is

we who plant this kudzu in the fertile soil of our federal sys-

tem.” 989 F.2d at 1519. We pass up yet another opportunity

to root out this weed. Instead, we feed it Miracle-Gro. I dis-

sent.

14910

http://www.ca9.uscourts.gov/ca9/newopinions.nsf/04485f8dcbd4e1ea882569520074e698/b3ec68ff03b90b06882569580068d047?OpenDocument

Case Name:WENDT V HOST INTERNATIONAL INC

Case Number: Date Filed:

96-55243 09/22/97

FOR PUBLICATION

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

GEORGE WENDT, an individual;

JOHN RATZENBERGER, an individual,

Plaintiffs-Appellants,

v.

No. 96-55243

HOST INTERNATIONAL, INC., a

D.C. No.

Delaware corporation;

CV-93-142-R

Defendant-Appellee,

OPINION

and

PARAMOUNT PICTURES CORPORATION,

a Delaware corporation,

Defendant-Intervenor.

Appeal from the United States District Court

for the Central District of California

Manuel L. Real, District Judge, Presiding

Argued and Submitted

March 11, 1997–Pasadena, California

Filed September 22, 1997

Before: Betty B. Fletcher and Stephen S. Trott,

Circuit Judges, and Bruce S. Jenkins,* District Judge.

Opinion by Judge Fletcher

_________________________________________________________________

*Honorable Bruce S. Jenkins, Senior United States District Judge for

the District of Utah, sitting by designation.

12347

SUMMARY

The summary, which does not constitute a part of the opinion of the court,

is copyrighted C 1994 by Barclays Law Publishers.

_________________________________________________________________

Intellectual Property/Entertainment

The court of appeals reversed a judgment of the district

court. The court held that actors have statutory and common-

law rights against the unauthorized use of their likenesses in

promotional figures based on an infringer’s copyrighted char-

acters.

Appellants George Wendt and John Ratzenberger are actors

who played the characters of “Norm” and “Cliff” in the

Cheers television series. They sued appellee Host Interna-

tional, Inc. alleging violations of their trademark and publicity

rights under Cal. Civ. Code S 3344 (liability for unauthorized

commercial use of person’s likeness), California common

law, and unfair competition under the Lanham Act. The com-

plaint alleged that Host had used their likenesses without

authorization in “animatronic,” i.e., robot, figures in airport

Cheers bars.

In Wendt I, the Ninth Circuit held that the state-law claims

were not preempted by federal copyright law, and that sum-

mary judgment for Host was inappropriate because the district

court’s comparison of photographs of Wendt and Ratzenber-

ger with photographs of the robots was insufficient to resolve

their claims under S 3344, and that the comparison had to be

made without reference to the context in which the images

appeared. The court also concluded that disputed issues of

material fact remained regarding the common-law claims

because the similarity between the actors’ physical character-

istics and those of the robots was disputed. Lastly, the court

ruled that the Lanham Act claims required the application of

a standard test to determine whether Host’s conduct created

a likelihood of confusion as to whether the actors were

endorsing Host’s product.

12348

On remand, Host again moved for summary judgment.

Wendt and Ratzenberger presented evidence of actual confu-

sion among members of the public in the form of comments

by travelers in airport Cheers bars. The district court excluded

their proffered consumer survey taken in the vicinity of

Cheers bars. Wendt and Ratzenberger also submitted evi-

dence that Host intentionally designed the robot figures to

resemble them because the value of the association of the

robots with them was “a major drawing card” of the Cheers

concept. Ratzenberger testified that he had rejected offers

from small breweries to appear in their advertisements in

order to be available to a large brewery.

The district court made an in-court comparison of Wendt

and Ratzenberger with the actual robots (now named “Hank”

and “Bob”), finding that there was no similarity except that

one was heavier than the other. The court granted Host’s

motion, dismissed the action, and awarded Host attorneys

fees.

Wendt and Ratzenberger appealed, contending that dis-

missal was inappropriate because material issues of fact

remained as to the degree to which the robots appropriated

their likenesses. They asserted that the likenesses did not have

to be identical or photographic, and that the determination of

the issue was for the jury. Wendt and Ratzenberger conceded

that they retained no rights to the characters Norm and Cliff,

but asserted that “Bob” and “Hank” were not related to Para-

mount’s copyright of the creative elements of the characters

Norm and Cliff. It was their contention that it was the physi-

cal likeness to them that had commercial value to Host.

Host countered that the figures appropriated only the identi-

ties of the characters of Norm and Cliff, to which intervenor

Paramount Pictures Corp. owned the copyrights, and not the

identities of Wendt and Ratzenberger. It was Host’s position

that Wendt and Ratzenberger could not claim appropriation of

12349

identity by relying on indicia like the Cheers bar set that were

the property of or licensed by a copyright owner.

[1] The degree to which the robots resembled, caricatured,

or bore an impressionistic resemblance to Wendt and Ratzen-

berger was material to the claim of violations ofS 3344. Sum-

mary judgment would have been appropriate on remand only

if no genuine issues of material fact concerning the degree of

that resemblance were raised by Wendt and Ratzenberger. [2]

Material facts existed that might have caused a reasonable

jury to find them sufficiently “like” Wendt and Ratzenberger

to violate S 3344.

[3] Wendt and Ratzenberger were not seeking to prevent

Paramount from exhibiting its copyrighted work in the Cheers

series. Their claims were not preempted by the copyright stat-

ute so long as they contained elements, such as the invasion

of personal rights, that were different in kind from copyright

infringement. As a general proposition, S 3344 is intended to

protect rights that cannot be copyrighted.

[4] California recognizes a common-law right of privacy

that includes protection against appropriation for the defen-

dant’s advantage of the plaintiff’s name or likeness. The right

is referred to as the “right of publicity.” A common-law cause

of action for appropriation of name or likeness may be alleged

by pleading (1) the defendant’s use of the plaintiff’s identity;

(2) appropriation of the plaintiff’s name or likeness to the

defendant’s advantage; (3) lack of consent; and (4) resulting

injury.

[5] This common-law right protects against more than

knowing use of a plaintiff’s name or likeness for commercial

purposes. It also protects against appropriations of the plain-

tiff’s identity by other means. [6] While it was true that

Wendt’s and Ratzenberger’s fame arose in large part through

their participation in Cheers, an actor does not lose the right

12350

to control the commercial exploitation of his or her likeness

by portraying a fictional character.

[7] Wendt and Ratzenberger raised genuine issues of mate-

rial fact concerning the degree to which the figures looked

like them. Because they did so, they also raised triable issues

as to whether Host sought to appropriate their likenesses for

its own advantage, and whether it succeeded. The issue for the

jury was whether the defendants were commercially exploit-

ing the likeness of the figures to Wendt and Ratzenberger

intending to engender profits.

[8] The Lanham Act prohibits the use of any symbol or

device that is likely to deceive consumers as to the associa-

tion, sponsorship, or approval of goods or services by another

person. Wendt’s and Ratzenberger’s claim was for false

endorsement–that by using an imitation of their unique phys-

ical characteristics, Host misrepresented their association with

and endorsement of the Cheers bar concept.

[9] To determine if it was likely that Host’s conduct created

a likelihood of confusion as to whether Wendt and Ratzenber-

ger were endorsing Host’s product, an eight-factor test

applied. This test required consideration of (1) the strength of

the plaintiff’s mark; (2) relatedness of the goods; (3) similar-

ity of the marks; (4) evidence of actual confusion; (5) market-

ing channels used; (6) likely degree of purchaser care; (7)

defendant’s intent in selecting the mark; and (8) likelihood of

expansion of the product lines.

[10] On remand, the district court simply compared the

robots with Wendt and Ratzenberger and awarded judgment

because there was no similarity. The court erred in failing to

analyze any of the other relevant factors to determine whether

there was a likelihood of confusion to consumers as to

whether Wendt and Ratzenberger sponsored, approved of, or

were otherwise associated with the Cheers bars. [11] The

Lanham Act’s likelihood of confusion standard is predomi-

12351

nantly factual. Summary judgment is inappropriate when a

jury could reasonably conclude that most of the factors

weighed in the plaintiff’s favor.

[12] The district court erred in rejecting the Lanham Act

claim at the summary judgment stage because a jury could

reasonably have concluded that most of the factors weighed

in favor of Wendt and Ratzenberger. They were principal

players on Cheers, a popular television show. They were well

known among the target customers of Host’s Cheers bars. A

jury could reasonably have concluded that their mark was

strong.

[13] For the same reasons, their “goods” (their skills and

fame as actors) were obviously related to Host’s “goods” (the

products sold in the Cheers bars and the bars themselves)

even if they were not strictly competitive. The issue was

whether a consumer would be confused as to Wendt’s and

Ratzenberger’s association with or sponsorship of Host’s bars.

The source of their fame and the Host bars was identical: the

Cheers television series.

[14] Similarity of the marks was the primary issue in dis-

pute. Because Wendt and Ratzenberger raised triable issues of

material fact concerning the degree to which the robots

resembled them, a reasonable jury might have found that this

factor weighed in their favor. Under the Lanham Act, in cam-

era inspection is not sufficient. The district court had to view

the marks as they appeared in the marketplace.

[15] Wendt and Ratzenberger presented evidence of actual

consumer confusion in their declarations and in the form of

survey evidence. This evidence should not have been

excluded. Sufficient evidence existed by which a reasonable

jury might have inferred actual consumer confusion.

[16] The factor of marketing channels used weighed in

favor of Wendt and Ratzenberger. The allegation that appro-

12352

priating their likenesses because the target audience of the

Cheers bars was customers who were fans of the television

series was a similarity in marketing channels that suggested

that there was at least a likelihood of consumer confusion.

[17] The factor of degree of purchaser care weighed in

favor of Wendt and Ratzenberger as well. Consumers were

not likely to be particularly careful in determining who

endorses or is affiliated with an airport bar in which they

might purchase a single beverage. They would be even less

likely to scrutinize the source of the figures used to attract

patrons. This low degree of care made confusion of sponsor-

ship likely.

[18] Wendt and Ratzenberger alleged facts that could have

given rise to an inference that Host intended to confuse cus-

tomers as to their sponsorship or endorsement of the Cheers

bars by creating robots with their physical characteristics.

Based on the evidence in opposition to summary judgment, an

inference could have been raised that Host intended to exploit

their celebrity by confusion as to the similarity between the

figures and Wendt and Ratzenberger.

[19] The factor of likelihood of expansion of product lines

weighed in Wendt’s and Ratzenberger’s favor as the potential

existed that in the future, Ratzenberger’s endorsement of

other beers would be confused with his alleged endorsement

of the beers sold at Host’s bars.

[20] A reasonable jury could have concluded that most of

the factors weighed in favor of Wendt and Ratzenberger, and

that Host’s conduct created at least the likelihood of consumer

confusion. Whether their Lanham Act claim should succeed

was a matter for the jury.

[21] In trademark cases, surveys are to be admitted as long

as they are conducted according to accepted principles and are

relevant. Challenges to methodology go to the weight given

12353

the survey, not its admissibility. On remand, the parties

should have the opportunity respectively to lay a foundation

for admission of the survey, or to challenge the adequacy of

the foundation.

_________________________________________________________________

COUNSEL

David A. Pash, Kinsella, Boesch, Fujikawa & Towle, Los

Angeles, California, for the plaintiffs-appellants.

William T. Rintala, Rintala, Smoot, Jaenicke & Rees, Los

Angeles, California, for the defendants-appellees.

Robert S. Chapman, Greenberg, Glusker, Fields, Claman &

Machtinger, Los Angeles, California, for the defendant-

intervenor.

_________________________________________________________________

OPINION

FLETCHER, Circuit Judge:

Actors George Wendt and John Ratzenberger appeal the

district court’s grant of summary judgment in favor of Host

International, Inc. (”Host”) and applicant in intervention Para-

mount Pictures Corporation (”Paramount”), dismissing their

action for violations of the Lanham Act, 15 U.S.C.S 1125(a),

and California’s statutory and common law right of publicity.