## Facts

- Twenty-four Mexican film-production companies claimed ownership of copyrights in 88 Mexican films produced from the 1930s to the 1960s.
- U.S.-based distributors acquired licenses from Mexican entities and distributed the films in the United States during the 1980s and continued distribution thereafter.
- Many films had entered the U.S. public domain due to noncompliance with then-applicable U.S. formalities (e.g., notice and renewal).
- Congress enacted the Uruguay Round Agreements Act (URAA), which automatically restored U.S. copyrights on January 1, 1996, for certain foreign works still protected in the source country but in the U.S. public domain for specified technical reasons.
- The studios asserted that, under Mexican law, they held “derecho de autor” in the films and thus the URAA restored U.S. copyrights in their favor; they alleged infringement based on defendants’ post-restoration distribution.
- The distributors argued that Mexican “author” status was limited to natural persons and that the studios could not be the restored rightsholders; they also challenged the studios’ proof of title for particular films.

## Issues

1. Whether Mexican law permits film-production companies to hold “derecho de autor” in cinematographic works, making them eligible foreign rightsholders for URAA restoration.
2. Whether the studios presented sufficient evidence of ownership for each film supporting the jury’s infringement findings.
3. Whether defendants’ continued exploitation after January 1, 1996 could avoid liability based on pre-restoration public-domain status or asserted defects in chain of title.
4. Whether alleged instructional, evidentiary, and foreign-law determinations required reversal as to any films or claims.

## Decision

- The Fifth Circuit reviewed foreign-law determinations de novo under Federal Rule of Civil Procedure 44.1 and evaluated the jury’s findings for evidentiary sufficiency.
- The court affirmed the central ruling that Mexican film-production companies can hold “derechos de autor” in cinematographic works under Mexican legal materials relied on at trial.
- The court held that URAA restoration operates automatically for eligible works and vests in the rightsholder defined by the source country’s law; thus, qualifying films could be enforced in U.S. courts by the Mexican rightsholders.
- The court found sufficient evidence supported the verdict for most films, based on contracts, corporate records, assignments, and historical exploitation evidence credited by the jury.
- The court affirmed most of the judgment, while modifying, reversing, vacating, or remanding in limited respects for particular titles or claims where proof or legal application was deficient.

## Legal Principles

- Determination of foreign law is a question of law for the court under Rule 44.1, reviewed de novo on appeal.
- URAA restoration (effective January 1, 1996) restores U.S. copyright in eligible foreign works that remain protected in the source country, even if previously in the U.S. public domain due to formalities failures.
- Restored rights vest in the foreign rightsholder as defined by the source country’s law; U.S. courts look to that law to identify the owner entitled to enforce restored copyrights.
- A defendant’s pre-restoration distribution does not bar infringement liability for post-restoration exploitation if restored rights vested in the plaintiff and infringement elements are proven.
- Ownership and chain-of-title disputes in infringement actions are fact questions for the jury when supported by admissible documentary and circumstantial evidence; appellate review does not reweigh credibility.

## Conclusion

The Fifth Circuit upheld that Mexican film producers could own authors’ rights under Mexican law and therefore could receive and enforce URAA-restored U.S. copyrights, supporting liability for defendants’ post-1996 distribution of most films, with limited film-specific adjustments on remand.


Alameda Films S.A. de C.V. v. Authors Rights Restoration Corp., 331 F.3d 472 (5th Cir. 2003)