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ARTICLE · 30 SEPTEMBER 2025

Ninth Circuit Strikes Cautionary Note For Studios In The AI Age In "Beast"-ly Decision

Manatt, Phelps & Phillips, LLP
Manatt, Phelps & Phillips, LLP
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On September 11, 2025, beauty was in the eye of the copyright holder, as the Ninth Circuit reinstated a 2023 jury verdict finding Walt Disney Pictures (Disney) vicariously liable...

United StatesTechnology
Nathaniel L. Bach
Nathaniel L. Bach
Andrea Del-Carmen Gonzalez
Andrea Del-Carmen Gonzalez

On September 11, 2025, beauty was in the eye of the copyright holder, as the Ninth Circuit reinstated a 2023 jury verdict finding Walt Disney Pictures (Disney) vicariously liable for its contractor's copyright infringement of visual effects software during the production of Disney's 2017 Beauty and the Beast film reboot. Reversing the district court's post-verdict grant of judgment as a matter of law for Disney, the Circuit Court found the plaintiffs (Rearden) presented sufficient evidence at trial for the jury to find that Disney had control over the infringing conduct.

The court's opinion reaffirms and further defines the contours of a defendant's duty to guard against infringement over which it may have some control. With artificial intelligence (AI) becoming increasingly integrated into the entertainment and technology industries, the opinion underscores potential new challenges for studios and technology providers.

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