Disney Impales Two Copyright Infringement Claims over Frozen

Frozen accused of copyright infringement based on two works titled The Snowman, and The Snow Princess.
March 29, 2016


Disney’s Frozen was released in 2013 and has since made over $1 billion internationally, is the 18th highest grossing film of all time, and remained in the top eight films for all fourteen weeks that it was in wide release. While Frozen was a monstrous financial success, Disney’s celebration would not last long. Two complaints were filed against Disney for copyright infringement soon after the film’s release. The most recent development in the Frozen lawsuits was the dismissal of a case brought by a Kuwaiti woman, Muneefa Abdullah, on March 17, 2016 by Judge Stephen Wilson of the United States District Court for the Central District of California.

Before this most recent development, Disney was preoccupied with a suit relating to the Frozen trailer featuring Olaf, the movie’s snowman sidekick. Kelly Wilson brought a copyright lawsuit in March 2014 alleging that Frozen was substantially similar to her 2D computer animated film, The Snowman, about a snowman dealing with hungry rabbits trying to eat his carrot nose. While the plotline of The Snowman is not the same as Disney’s Frozen, the suit focused on film commentators mistaken impressions of what they thought the movie was about. One commentator stated that his daughter thought the movie was about a snowman and reindeer fighting over a carrot. Wilson submitted to the court alleged similarities in plot, characters, themes, sequences of events, setting, and dialogue. While the standard for showing substantial similarity is a high one, Disney’s motion to dismiss was denied by the United States District for the Northern District of California because the judge believed the two works were “too parallel to conclude that no reasonable juror could find the works substantially similar.” Disney then filed a motion for summary judgment and used YouTube records to show that the creators of the Frozen trailer lacked access to The Snowman. This argument also failed because the judge held there was a genuine factual dispute over whether the creators of the Frozen trailer had access to The Snowman. On June 10, 2015, the two warring snowmen finally came to a resolution out of court, the details of which were not revealed.

The settlement between Disney and Wilson came on the heels of another suit filed by Muneefa Abdullah in April 2015. Abdullah claimed that Frozen took plot points from her story, The Snow Princess. However, Abdullah’s suit was frozen in its tracks on March 14, 2016, when the District Court for the Central District of California granted Disney’s motion to dismiss. Judge Stephen Wilson compared the over one-and-a-half-hour film to the nine-page story and found that the similarities between the two works were merely mischaracterizations, scenes a faire, and generic plot points found in numerous works such as The Lord of the Rings and Shrek. Judge Wilson concluded that, “at its core, The Snow Princess is a short story about an evil mountain witch who abducts a princess, and a pair of princes who rescue her. Frozen is a full-length film about a princess who learns to control her powers through self-acceptance and love, and a celebration of sisterhood.”

Sean O’Connell, Frozen’s 5 Most Mind-Blowing Accomplishments, CinemaBlend. http://www.cinemablend.com/new/Frozen-5-Most-Mind-Blowing-Accomplishments-41974.html.
Ashley Cullins, Hollywood Docket: Rolling Stone Source Deposition; ‘Frozen’ Lawsuit Chilled; Univision Sued Over ‘Machete’, The Hollywood Reporter, March 16, 2016. http://www.hollywoodreporter.com/thr-esq/hollywood-docket-rolling-stone-source-876225.
Eriq Gardner, Disney Loses Second Attempt to Beat ‘Frozen’ Lawsuit, The Hollywood Reporter, April 17, 2015. http://www.hollywoodreporter.com/thr-esq/disney-loses-second-attempt-beat-789593.
Eriq Gardner, Disney’s ‘Frozen’ Trailer Targeted in Copyright Lawsuit, The Hollywood Reporter, March 31, 2014. http://www.hollywoodreporter.com/thr-esq/disneys-frozen-trailer-targeted-copyright-692267.
Eriq Gardner, Lawsuit Over Disney’s ‘Frozen’ Trailer Heats Up After Judge Rejects Dismissal, The Hollywood Reporter, July 31, 2014. http://www.hollywoodreporter.com/thr-esq/lawsuit-disneys-frozen-trailer-heats-722519
Gardner, supra note 3.
Sarah Begley, Frozen Story Was Stolen, Author Claims, Time, April 16, 2015. http://time.com/3824803/frozen-copyright-lawsuit/.
Cullins, supra note 2.