Article: California Misappropriation Claim Not Pre-Empted By Copyright Act.

Addressing whether the U.S. Copyright Act would pre-empt a claim for misappropriation under California state law, the U.S. Court of Appeals for the Ninth Circuit vacated the ruling of the lower court and found that the state claim could proceed. Stewart Title of California Inc. v. Fidelity National Title Co., Case No. 06-55955 (9th Cir., May 19, 2008) (Pollak, J., sitting by designation) (non-precedential).

In Stewart, plaintiff Stewart Title of California (Stewart), a real estate service company, sued defendant Fidelity National Title (Fidelity) for copyright infringement, unfair competition and misappropriation for using sales contract and disclosure ...

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