are THE BIG PLAYERS OF THE ENTERTAINTMENT INDUSTRY against ai?











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aintiffs: y Enterprises, Inc., Marvel Characters, MVL Film Finance LLC, Lucasfilm Ltd. Twentieth Century Fox Film ration, Universal City Studios ctions LLLP, and DreamWorks tion L.L.C., allege that Midjourney, Inc. engaged in direct and secondary ght infringement.

The plaintiffs provide extensive materials to support their claims of copyright infringement by Midjourney, including:


The plaintiffs provide extensive materials to support their claims of copyright infringement by Midjourney, including:


The plaintiffs provide extensive materials to support their claims of copyright infringement by Midjourney, including:


The plaintiffs provide extensive materials to support their claims of copyright infringement by Midjourney, including:











NTERPRISES, INC.,
AL CITY STUDIOS PRODUCTIONS LLLP
BROS. ENTERTAINMENT INC.,
CHARACTERS, INC.,
M FINANCE LLC
TH CENTURY FOX FILM CORPORATION,
LM LTD. LLC, CS
TOON NETWORK, INC.
BARBERA PRODUCTIONS, INC.,
WORKS ANIMATION L.L.C.





Minimax? MiniMax is a Shanghai-based intelligence company founded in 2021 by enseTime executives.
multimodal AI models capable of generating ssing text, images, audio, and video with ch as Hailuo AI
major investors like Alibaba, the company has reds of millions of dollars. It is considered one eading “AI Tiger” startups,


MiniMax markets Hailuo AI as a “Hollywood studio in your pocket” The Hailuo service offers its subscribers an endless supply of infringing images and videos featuring Plaintiffs’ famous copyrighted characters.


MiniMax markets Hailuo AI as a “Hollywood studio in your pocket” The Hailuo service offers its subscribers an endless supply of infringing images and videos featuring Plaintiffs’ famous copyrighted characters.






Direct Copyright Infringement: These platforms unlawfully reproduced, publicly displayed, distributed, and created derivative works based on the plaintiffs' copyrighted characters and works without authorization. This includes using plaintiffs' works to train its AI Image Service and generating infringing outputs for subscribers.
Secondary Copyright Infringement: Even if Defendants were to argue their subscribers are the direct infringers, the plaintiffs claim the Defendants are vicariously liable for enabling and profiting from the infringement. espcially considering they have allegedly failed to implement reasonable measures to prevent infringement, despite having the ability to do so.

Willful Infringement: The plaintiffs assert that Defendants’ actions are intentional and disregard their rights, as evidenced by its continued infringement even after receiving cease-and-desist letters.
Unfair Competition: Defendants' conduct undermines the plaintiffs' licensing markets and confuses consumers about the legality of its outputs

The plaintiffs provide extensive materials to support their claims of copyright infringement
Unauthorized Outputs: Defendants’ AI Image Service generates outputs that reproduce, publicly display, and distribute copies and derivatives of the plaintiffs' copyrighted characters, such as Yoda, Darth Vader, Minions, Spider-Man, Elsa, and Shrek, among others.
Training on Copyrighted Works: The plaintiffs allege that Defendants trained its AI model using their copyrighted works without authorization. Defendants’ ability to generate highquality, faithful reproductions of the plaintiffs' characters demonstrates that their works were used in the training process.

The plaintiffs provide extensive materials to support their claims of copyright infringement by Midjourney, including:
Prompts and Outputs: Specific examples of prompts (e.g., "Yoda with lightsaber, IMAX" or "Minions in the film Despicable Me, screencap") and the corresponding outputs are provided, showing clear similarities to the plaintiffs' copyrighted characters.
Public Display on Explore Page: Defendants publicly displays infringing images on its "Explore" page, which is accessible to subscribers and non-subscribers. Searches for terms like "Iron Man," "Minions," or "The Simpsons" yield numerous infringing images.






28 U.S.C. §§ 1331, 1332, 1338(a), and 17 U.S.C. § 501(b).
Court has personal jurisdiction over MiniMax, SXJT, and Nanonoble Pte. Ltd pursuant to Federal Rule of Civil Procedure 4(k)(2) because they each have purposefully directed their activities at the United States, California, and this District, and have purposefully availed themselves of the benefits of doing business in the United States, California, and this District as detailed below.
MiniMax distributes its infringing Hailuo AI service in the United States, California, and this District as an app through the Apple App Store and Google Play Store, both operated from California.

MiniMax has availed itself of United States’ intellectual property laws and protection by filing several trademark applications in the United States Patent and Trademark Office for Hailuo AI.
In trademark applications for the mark “Hailuo,” MiniMax confirms that it intends to use its Hailuo mark in commerce in the United States for “software for creating and editing music and video by artificial intelligences.”


