Editing Choreography (section)

==Copyright Protection of Choreography==

Section 102(a)(4) of the Copyright Act protects "choreographic works" created after January 1, 1978, and fixed in a tangible medium of expression.<ref>{{Cite web |title=17 U.S. Code § 102 – Subject matter of copyright: In general |url=https://www.law.cornell.edu/uscode/text/17/102 |access-date=2023-12-12 |website=LII / Legal Information Institute |language=en}}</ref> Under copyright law, choreography is "the composition and arrangement of a related series of dance movements and patterns organized into a coherent whole."<ref>The U.S. Copyright Office, ''Copyright Registration of Choreography and Pantomime'', Copyright Office's Circular 52 (Oct. 2022), https://www.copyright.gov/circs/circ52.pdf .</ref> Choreography consisting of ordinary motor activities, social dances, commonplace movements or gestures, or athletic movements may lack sufficient authorship to qualify for copyright protection.<ref>The U.S. Copyright Office, ''Copyright Registration of Choreography and Pantomime'', Copyright Office's Circular 52 (Oct. 2022), https://www.copyright.gov/circs/circ52.pdf .</ref>

A recent lawsuit was brought by professional dancer and choreographer Kyle Hanagami, who sued Epic Games, alleging that the video game developer copied a portion of Hanagami’s copyrighted dance moves in the popular game Fortnite.<ref name=":0">{{Cite web |title=Hanagami v. Epic Games Inc. {{!}} Loeb & Loeb LLP |url=https://www.loeb.com/en/insights/publications/2022/09/hanagami-v-epic-games-inc |access-date=2023-12-12 |website=loeb.com |language=en}} </ref> Hanagami published a YouTube video in 2017 featuring a dance he choreographed to the song "How Long" by Charlie Puth, and Hanagami claimed that Fortnite's "It's Complicated" "emote" copied a portion of his "How High" choreography.<ref name=":0" /> Hanagami asserted claims for direct and contributory copyright infringement and unfair competition.<ref name=":1">{{Cite web |title=Hanagami v. Epic Games Inc. {{!}} Loeb & Loeb LLP |url=https://www.loeb.com/en/insights/publications/2022/09/hanagami-v-epic-games-inc |access-date=2024-02-29 |website=loeb.com |language=en}} </ref> Fortnite-maker Epic Games ultimately won dismissal of the copyright claims after the district court concluded that his two-second, four-beat sequence of dance steps was not protectable under copyright law.<ref name=":1" />