I. Introduction
The animated film ‘Moana’ released by Disney (2016) is widely celebrated for its stunning animation, compelling storyline, and cultural representation of Polynesian heritage. However, the movie has also become the centre of a significant legal controversy. A recent lawsuit, lodged in a California federal court, by an animator Buck Woodall alleging that Disney stole key elements from their original work, to create ‘Moana’ and its sequel, led to a staggering $10 billion legal claim. This case raises significant issues in entertainment law, particularly regarding copyright infringement and intellectual property theft. Let’s know more about the Moana Copyright Case:
II. Background of the Lawsuit
The lawsuit was filed by an independent animator ‘Buck Woodall’ who claims that Disney unlawfully used their original work ‘Bucky’ as the foundation for ‘Moana’. This is not Woodall’s first attempt at legal action; he previously filed a lawsuit regarding the ‘Moana’ film but lost in November 2024 due to the passing of the statute limitations. However, the release of ‘Moana 2’ has allowed him to revive his claims.
Woodall asserts that he shared his screenplay, trailer, character designs, and other materials with Jenny Marchick, a former executive at Mandeville Films, during the early 2000s when Mandeville was closely collaborating with Disney. Disney, on the other hand, has categorically denied the allegations, stating that Moana was independently developed through extensive research on Polynesian culture and mythology.
The lawsuit demands $10 billion in damages, citing not only copyright infringement but also unjust enrichment and reputational harm.
III. Legal Framework for Copyright Infringement
In the entertainment industry, copyright serves to ensure that creators retain control over their intellectual property and receive fair compensation for their work. For a claim of copyright infringement to be successful, the plaintiff must prove the following key elements:
- Ownership of Copyrighted Work: The plaintiff must establish a valid copyright over the allegedly stolen content by demonstrating that their work is an original creative expression, protected under copyright law. This requires proving that the work was independently created and possesses a sufficient degree of creativity to qualify for legal protection.
- Copying and Substantial Similarity: The plaintiff must demonstrate that the defendant copied creative elements of the work and that the similarities are substantial enough to constitute infringement.
- Lay Observer’s Test: Also called “the audience test,” this determines infringement by assessing whether a layman finds the works so similar that they are indistinguishable, making the defendant’s work ineligible for independent copyright protection.
- Access to the Work: The plaintiff must show that Disney had access to their work before creating Moana. This could be proven through meetings, email exchanges, or prior submissions to Disney.
IV. Plaintiff’s Allegations
Woodall claims that the similarities between ‘Bucky’ and ‘Moana’ are too pronounced to be coincidental and suggests that Disney’s development of ‘Moana’ relied heavily on the materials he provided.
The lawsuit identifies several parallels between Bucky and Disney’s films including a protagonist who begins their journey with a turtle, the presence of a symbolic necklace, encounters with a demigod characterized by tattoos and wielding a hook, a giant creature concealed within a mountain and in Moana 2, the protagonist’s quest to break a curse and search for an ancient island closely mirrors elements from Bucky, according to Woodall.
V. Disney’s Response
Disney has firmly denied all allegations, asserting that none of their creators were influenced by or had access to Woodall’s work. Director Ron Clements emphasized that ‘Moana’ was developed independently, without inspiration from Woodall’s project. The studio has presented documents outlining how ‘Moana’ originated and evolved, aiming to demonstrate their creative process was distinct from Woodall’s screenplay.
VI. Rulings in Indian Landmark cases
1) MRF Limited v. Metro Tyres Limited [CS(COMM) 753/2017]https://indiankanoon.org/doc/78110318/
In this case, the court held “There can be no copyright in an idea, subject matter, themes, plots or historical or legendary facts and violation of the copyright in such cases is confined to the form, manner and arrangement and expression of the idea by the author of the copyright work.
Where the same idea is being developed in a different manner, it is manifest that the source being common, similarities are bound to occur. In such a case the courts should determine whether or not the similarities are on fundamental or substantial aspects of the mode of expression adopted in the copyrighted work. If the defendants work is nothing but a literal imitation of the copyrighted work with some variations here and there it would amount to violation of the copyright. In other words, in order to be actionable the copy must be a substantial and material one which at once leads to the conclusion that the defendant is guilty of an act of piracy.
One of the surest and the safest test to determine whether or not there has been a violation of copyright is to seeing the reader, spectator or the viewer after having read or seen both the works is clearly of the opinion and gets an unmistakable impression that the subsequent work appears to be a copy of the original.”
The court emphasised that when a common idea is developed in different ways, similarities are inevitable. However, what matters is whether the similarities exist in the fundamental and substantial aspects of the copyrighted work’s expression.
2) R.G. Anand v. Deluxe Films [4 SCC 118 (1978)] https://indiankanoon.org/doc/1734007/
To determine the originality of a film, the Court referred to the test laid down in this landmark case wherein it was held that in such matters, the Court must compare “the substance, the foundation, the kernel” of the two films in question. It is imperative to understand whether an average viewer who is made to watch both the films would get the unmistakable impression that one is the copy of the other.
VII. Conclusion
The $10 billion Moana lawsuit raises critical questions about intellectual property rights in the entertainment industry. While independent creators deserve protection for their work, proving copyright infringement against a media giant like Disney remains a formidable challenge.
The case highlights the ongoing struggle between creative individuals and corporate studios, highlighting the need for sturdier legal measures and ethical industry practices. Whether Disney is ultimately found liable or not, the lawsuit serves as a reminder of the importance of transparency, originality, and fair recognition in storytelling.
As the legal battle unfolds, it will be fascinating to see how the court navigates the intersection of copyright law, cultural heritage, and creative ownership in one of the most high-profile infringement cases in recent years.
AUTHOR: MS. PRACHI RAI, LAW STUDENT AT AMITY UNIVERSITY MADHYA PRADESH
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