Pamella Lawrence v. Sony Pictures Entertainment

MEMORANDUM

Pamella Lawrence appeals the district court’s grant of summary judgment for Defendants and the district court’s grant of Defendants’ motion for attorneys’ fees. We have jurisdiction under 28 U.S.C. § 1291 , and we affirm.

Lawrence argues that the district court erred in granting summary judgment for Defendants on her copyright infringement claims. With regard to Lawrence's claim that the Death at a Funeral films infringed her copyright to "Caught on Video" ("the Video"), Lawrence has failed to raise a genuine issue of material fact that she owned a valid copyright to the Video. See CDN Inc. v. Kapes, 197 F.3d 1256, 1258 (9th Cir.1999). The copyright to the Video initially vested in Orlando Usher, the author of the Video, 17 U.S.C. § 201 (a); see also S.O.S., Inc. v. Payday, Inc., 886 F.2d 1081, 1085 (9th Cir.1989), and was not validly transferred to Lawrence because any transfer of rights was not done in writing, 17 U.S.C. § 204 (a); see also Konigsberg Int'l Inc. v. Rice, 16 F.3d 355, 357-58 (9th Cir.1994). Although Lawrence has since obtained a copyright registration for the Video, it was not "made before or within five years after first publication of the work." 17…