Summary Judgment Affirmed-No Valid Transfer Of Copyright.

The author of a work called The Match was also the owner of a copyright for the work. The lawyer for an entertainment agency proposed certain terms to the lawyer for the copyright owner and sent a writing:  “Let me know if this is okay and we’ll send paperwork.” The lawyer for the owner of the copyright responded:  “done . . . thanks!” A written agreement was sent, but never signed. When the parties later disagreed and litigation ensued, the entertainment agency claimed the parties had entered into a contract for the entertainment company to make a movie of The Match. The trial judge entered summary judgment against the entertainment agency because it failed to raise a triable issue of material fact that it had a valid transfer of copyright under 17 U.S.C. §204(a). The appellate court agreed, noting there was no evidence the purported transfer was signed by the author or his duly authorized agent “evidence of which was essential to each of a [the entertainment agency’s] causes of action.” MVP Entertainment v. Mark Frost  (Cal. App. Second Dist., Div. 8; November 7, 2012) (Case No. B235100) 210 Cal.App.4th 1333, [149 Cal.Rptr.3d 162].