Melchior v. New Line Productions, Inc

In Melchior v. New Line Productions, Inc. (2003) 106 Cal.App.4th 779, an author brought an action against the assignee of the film production company to which he had optioned his rights to Lost in Space, a motion picture based on his story. (Id. at pp. 783-784.) He alleged causes of action for breach of contract, declaratory relief and accounting, conversion, and unjust enrichment. (Id. at p. 785.) The Court of Appeal held the plaintiff could not state a claim for conversion of the idea upon which the movie was based, stating: "The tort of conversion does not apply to ideas. Moreover, the courts have held that copyright protection does, in fact, extend to ideas. The plaintiff thus has no cause of action for conversion based upon defendant's use of his ideas." (Id. at p. 793.)