New Ninth Circuit Rulings on Implied-Contract Claims Provide Guidance for Idea-Submission Cases

In 2004, the U.S. Court of Appeals for the Ninth Circuit decided that state implied-in-fact contract claims weren't preempted by federal copyright law. <i>Grosso v. Miramax Film Corp.</i> The ruling resulted in a predictable increase in idea-submission suits over TV and film productions. But few judicial opinions since have cited <i>Grosso</i>. In June 2010, however, the Ninth Circuit issued two decisions ' with differing results ' that, by also drawing from precedents from decades before, illuminate how a court should consider the elements of an implied-contract case.

21 minute readJune 30, 2010 at 09:46 AM
By
Amanda Bronstad
& Stan Soocher
New Ninth Circuit Rulings on Implied-Contract Claims Provide Guidance for Idea-Submission Cases

In 2004, the U.S. Court of Appeals for the Ninth Circuit decided that state implied-in-fact contract claims weren't preempted by federal copyright law.Grosso v. Miramax Film Corp., 383

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