Lindsay v. The Wrecked and Abandoned Vessel R.M.S. Titanic 52 U.S.P.Q.2d 1609 (S.D.N.Y. 1999) Lindsay wanted to make a documentary about a sunken ship. He tagged along with a salvage team, and used them to help film the documentary. Lindsay created storyboards, specified specific camera angles and shooting sequences, directed, and produced the film. He remained on the ship while salvage divers in submarines went down and actually shot the video. The crew of the salvage vessel later licensed some of the footage they shot to a tv channel. Lindsay sued for copyright infringement. The crew argued that they were the ones who shot the video, so it was theirs to license as they willed. Lindsay argued that he was the actual author of the video, so he owned the copyright. The Trial Court found for Lindsay. The Trial Court found that even though Lindsay did not hold the video camera, he was the 'creative force' behind the video, and so was the author for copyright purposes. The Court likened this decision to that of Burrow-Giles Lithographic Co. v. Sarony (111 U.S. 53 (1884)) where it was held that a photographer can have a copyright on a photograph even though they didn't create the thing they were photographic. In both that case and this one, it was the selection of what to photograph that was the 'artistry', not the physical mechanism that captured the images. This case is misleading because it was really an oversimplification of copyright law. The crew could have argued that since multiple parties were involved in the creation of the work, the work should be considered a joint authorship. It could also have been considered a work for hire. However, the Court did not address either of these issues in their decision.