The 9th Circuit Court of Appeals rejected a copyright lawsuit on Monday that alleged that Pixar’s 2015 film “Inside Out” was based on the work of a child development expert.
Denise Daniels filed suit in 2017, alleging that Pixar had ripped off her idea for a TV show called “The Moodsters.” She assembled a creative team and produced a pilot for the show, in which color-coded characters represented each of five emotions: happiness, sadness, anger, love and fear.
Daniels alleged that she had pitched the idea to various Disney executives from 2005 to 2009. “Inside Out,” which began development in 2010, also featured characters that represented five emotions: joy, sadness, anger, fear, and disgust.
In its ruling on Monday, a three-judge panel of the 9th Circuit affirmed a lower court’s ruling dismissing the complaint. Writing for the panel, Judge Margaret McKeown held that Daniels’ characters were not sufficiently distinct to warrant copyright protection.
“Developing a character as an anthropomorphized version of a specific emotion is not sufficient, in itself, to establish a copyrightable character,” McKeown wrote.
The panel noted that characters like James Bond and Godzilla can be copyrighted if they “maintain consistent and identifiable character traits and attributes across various productions and adaptations.”
But, McKeown wrote, simply representing different emotions with different colors is not enough.
“Daniels cannot copyright the idea of colors or emotions, nor can she copyright the idea of using colors to represent emotions where these ideas are embodied in a character without sufficient delineation and distinctiveness,” the judge wrote.
The court relied on a test elaborated in a 2015 case, DC Comics v. Towle, in which the court found that a manufacturer of Batmobile replica cars was infringing on the copyrighted Batmobile character.