LIBEL AND SLANDER - SLANDER OF TITLE AS A PROTECTION AGAINST UNFAIR INTERFERENCE WITH SALE OF LITERARY WORK

In a slander of title action, the complaint alleged that defendant requested plaintiffs to write a motion picture scenario based on historical events, but after plaintiffs submitted the scenario, defendant rejected it. Thereafter defendant announced its intention, by filing a statement with a voluntary association of motion picture producers, to produce a picture based on the same plot as that contained in plaintiffs' scenario. As a result, plaintiffs were unable to sell their scenario to any other producer. Held, that the complaint was insufficient in the absence of an allegation of special damages.

Carrol v. Warner Bros. Pictures, Inc., (D. C. N. Y. 1937) 20 F. Supp. 405.