Hanna-Barbera Productions, Inc. v. Screen Gems-Emi Music Inc.
Plaintiff Hanna-Barbera Productions, Inc. sued Screen Gems-EMI Music Inc., Colgems-EMI Music Inc. (collectively EMI), and Broadcast Music, Inc. (BMI) for copyright infringement and state law violations. EMI moved to dismiss the complaint for lack of subject matter jurisdiction, arguing that the claims were primarily based on contract law, not copyright law. The court applied the three-part Schoenberg v. Shapolsky Publishers, Inc. test, determining that Hanna-Barbera's infringement claim was incidental to contract disputes, not a breach of a condition to a copyright contract, and EMI's actions did not constitute a material breach creating a right of rescission. The court found that the central issue revolved around the interpretation of contracts regarding copyright ownership and revenue distribution, which falls under state contract law. Therefore, the court granted EMI's motion, dismissing both federal and state claims for lack of subject matter jurisdiction.