Steinberg v. Columbia Pictures Industries, Inc.

The defendants, including Columbia Pictures Industries, Inc., RCA Corporation, and several major newspapers, denied Steinberg's allegations of copyright infringement and asserted the affirmative defenses of (1) fair use as a parody, (2) estoppel, and (3) laches.

The drawing, which appeared on the cover of the March 29, 1976 issue of The New Yorker, depicts four city blocks of Manhattan in great detail, with the rest of the United States and the world sketched sparsely in the background.

The Moscow on the Hudson poster featured the movie's lead actor Robin Williams and his two co-stars at the bottom of the frame, with a highly detailed depiction of four city blocks of Manhattan behind them.

In the background is a blue stripe representing the Atlantic Ocean, three landmarks denoting cities in Europe, and a set of Russian-looking buildings labeled "Moscow".

As examples, the court cited the angle, layout, and details of the four city blocks depicted; the use of color on the horizon and sky; the distinctive lettering used in both for place names as well as the title at the top; and the overall stylistic impression of the two works.

The court rejected the argument that any similarity between the works involved unprotectable scènes à faire, or standard themes common to any depiction of New York.

Finally, the defendants claimed the affirmative defense of laches, asserting that Steinberg had waited over six months to complain to Columbia Pictures about the alleged infringement in order to increase his award in the eventual lawsuit.