Grosso v. Miramax applied

NY Times: Lawyer Is Upping the Ante in Claims of Idea Theft in Hollywood: "The latest in a long line of gadflies who contend that it’s their job to keep the studios honest, Mr. Marder has spent the last two years capitalizing on having won a federal appeals court decision that makes it easier for writers who pitch an idea or circulate a script to make a claim of theft stick."

This Times article discusses the effect of the 9th Circuit's ruling in Grosso v. Miramax (2004).

The Patry Copyright Blog: Grosso Mondo: Bad Ideas Never Die: "Bad Ideas never die; no I'm not talking about the proposal to extend protection to fashion designs, but to protecting ideas themselves."