## Facts

- Kelvin Williams, doing business as Uprise Productions, worked as a music video director/editor and alleged he created and directed footage and a concept for a Cash Money Records music video project.
- Williams alleged defendants used his creative work without proper credit or compensation and credited others as the director.
- He claimed the miscrediting harmed his reputation and ability to obtain work in the music video industry.
- Williams asserted a federal claim under Lanham Act § 43(a), alleging false designation of origin/false representation based on misrepresentation of authorship/credit in the marketplace.
- UMG and related entities had a manufacturing and distribution relationship with Cash Money for Cash Money products.

## Issues

1. Whether a Lanham Act § 43(a) claim based on misattribution of authorship/credit for a creative work states a viable “false designation of origin” claim after Dastar Corp. v. Twentieth Century Fox Film Corp.
2. Whether the intervening Supreme Court decision in Dastar justified reconsideration of an earlier order that allowed the Lanham Act claim to proceed.

## Decision

- The court granted the moving defendants’ motion for reconsideration of the prior order that had allowed the Lanham Act claim to survive.
- The court dismissed Williams’s Second Claim for Relief under 15 U.S.C. § 1125(a) against the moving defendants.
- The court held that, under Dastar, the Lanham Act’s “origin of goods” language concerns the producer of tangible goods offered in commerce, not the author of the ideas or expressive content embodied in those goods.
- Because Williams’s theory was fundamentally a “credit” or authorship-attribution dispute, it was not cognizable under § 43(a).

## Legal Principles

- Under Lanham Act § 43(a)(1)(A), “origin of goods” refers to the producer of the tangible goods sold in commerce, not the creator of the expressive content contained in those goods.
- A claim alleging failure to attribute proper creative credit (or attribution of credit to someone else) is not a “false designation of origin” claim under § 43(a) after Dastar.
- Reconsideration is appropriate when there is an intervening change in controlling law that undermines the legal basis for a prior ruling.

## Conclusion

The court, applying Dastar, ruled that the Lanham Act does not provide a federal cause of action for misattribution of creative authorship in a music video and, based on the intervening change in controlling law, reconsidered and dismissed the plaintiff’s Lanham Act claim against the moving defendants.


Williams v. UMG Recordings, Inc., 281 F. Supp. 2d 1177 (C.D. Cal. 2003)