Project Runway v. American Runway: Heidi Klum Not Guilty of Copyright Infringement

Holding:

In this battle of fashion shows, the U.S. District Court for the Southern District of New York ruled that Heidi Klum's Project Runway program did not infringe the copyrighted treatment of Plaintiffs Cynthia Rodriguez and Elizabeth Zwiebach for their show American Runway. Specifically, the District Court gave two basic reasons for granting the motion for summary judgment filed by Defendants, led by Heidi Klum Company, LLC. First, Plaintiffs were unable to establish actual copying by Defendants because of Plaintiffs' failure to demonstrate access. Second, the concept, feel, and theme of Project Runway are plainly distinguishable from those of American Runway. Project Runway does not ostensibly bend to its audience; the viewer is given a glimpse into the world of high fashion and is allowed to watch fashion experts decide which of the contestants deserves admission into the industry. On the other hand, American Runway is more populist and inclusive; the viewer has input into the outcome of the show, and the program caters to engaging the fashion sensibilities of its real American audience.

Detailed Summary:

This action arose from the broadcast of the fashion themed reality television program Project Runway. Plaintiffs Rodriguez and Zwieback contended that the program infringed on a copyrighted treatment (“Treatment”) they created for a show called American Runway. Plaintiffs demanded damages for the alleged infringement of their copyright under 17 U.S.C. section 101, et seq. Order, p. 1.

Defendants Heidi Klum Co., LLC, Miramax Film Corp. (“Miramax”), Weinstein Company, LLC (“Weinstein Co.”), The Walt Disney (“Disney”), and NBC Universal, Inc. (“NBC”) (collectively, “Defendants”) moved for summary judgment under Rule 56 of the Federal Rules of Civil Procedure.

The issue here was whether…

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