Lindsay v. Wrecked & Abandoned Vessel R.M.S. Titanic
United States District Court for the Southern District of New York
52 U.S.P.Q.2d 1609 (1999)
Lindsay (plaintiff), after directing a documentary about the Titanic wreck's salvage, planned a later filming project at the wreck site using high-illumination lighting equipment mounted on custom-designed underwater towers he spent weeks directing the creation and placement of, along with detailing shot angles and equipment choices; others physically carried out his instructions and captured the actual footage. RMST (defendant), which owned rights to the wreck salvage, licensed the resulting footage to the Discovery Channel, prompting Lindsay to sue for copyright infringement; RMST moved to dismiss.
Whether an individual will qualify as an author for copyright purposes if he or she exercises a high degree of control over a work's creation.