IP Law Daily, COPYRIGHT—D.D.C.: Independent creation, or just another Wednesday? Lawsuit involving Addams Family character leaves question unanswered, (Mar 30, 2026)

By Matthew Hersh, J.D.

The lawsuit, which challenged the copyrightability of the famous Addams Family character, was tossed for procedural irregularities.

A self-published author who claimed that a famous cartoon and television character could not independently be the subject of copyright protection was properly rebuffed by the Copyright Claims Board, the District Court for the District of Columbia has found. The court, in rejecting the author’s lawsuit against the Board, found that he had lodged nothing more than “a hodgepodge of legal catchphrases” in his complaint and that he had not met the pleadings standards set forth in the statute governing federal court oversight of the Board (Santora v. Copyright Claims Board, No. 25-1055-TJK (D.D.C. Mar. 26, 2026)).

The lawsuit was brought by Francesco Santora, the author of a series of books based on the “Wednesday” character from the one-time comic strip (and later television series and Netflix revival) The Addams Family. One of those books (seemingly either “Child of Woe” or “The Haunted Clock;” the court papers are not clear), which Santora had published on Amazon, was the subject of a takedown notice by Metro-Goldwyn-Mayer Studios. Santora responded to the takedown notice by bringing a claim against MGM in the Copyright Claims Board, the federal tribunal established by Congress in 2020 to hear low-dollar copyright disputes as an alternative to federal court litigation.

The proceedings before the Board went through several different procedural rounds before ending unfavorably for the self-published author. Santora’s claim before the Board, as eventually amended, sought a declaration of noninfringement as to his copyrighted book, and also brought a misrepresentation claim against MGM under 17 U.S.C. § 512(f). Santora also immediately filed a series of motions seeking relief from the takedown notices and sanctions against MGM for its alleged bad faith conduct. The Board denied each of those motions as untimely and meritless.

Meanwhile, Tee & Charles Addams Foundation, ostensibly the owner of the intellectual property in the Addams Family franchise, moved to intervene in the case and eventually filed, along with MGM, a response to the complaint as well as a counterclaim for copyright infringement. Santora then failed to meet a series of procedural deadlines established by the Board, among other things missing a status conference and failing to timely respond to the counterclaim. The Board then dismissed his claim for failure to prosecute—and for good measure, found that he had engaged in “bad-faith conduct” and barred him from pursuing any claims before it for a year.

But that was not the end of the procedural wrangling. While the Board proceedings were still underway, Santora also brought a claim before the federal court. His pro se claim, as eventually amended after the Board proceedings were concluded, alleged violations under the Administrative Procedure Act and a series of “ultra vires actions,” including “fraud adjudication,” “copyrightability ruling,” and “bad faith merits ruling.” The complaint, which named the Board as a defendant, alleged a wide range of procedural irregularities. It also claimed that the Board had unlawfully “assumed power to decide whether Wednesday Addams is independently copyrightable—an issue with billion-dollar consequences.”

The Claims Board moved to dismiss the complaint, leading to this opinion.

Motion to dismiss. The court easily granted the motion to dismiss. Under the federal statute establishing the Board, the court noted, federal courts may vacate, modify or correct a “final or amended final determination” only in these cases: (1) “the determination was issued as a result of fraud, corruption, misrepresentation, or other misconduct”; (2) if the Board “exceeded its authority or failed to render a final determination concerning the subject matter at issue”; and (3) “[i]n the case of a default determination or determination based on a failure to prosecute,... it is established that the default or failure was due to excusable neglect.” 17 U.S.C. § 1508(c). Santora met none of these requirements.

Indeed, the court found Santora’s operative complaint—“a hodgepodge of legal catchphrases and references to the proceedings before the Board,” and the court observed—failed to allege a justiciable claim for relief for several reasons. While it alleged that the Board improperly handled the proceeding before it, the court noted, the complaint “never identifies a ‘final or amended final determination’ it challenges along with facts that would otherwise satisfy the requirements of § 1508(c).” Moreover, the court noted, the complaint never explained just how the determination fell short of the standards in that statute. “[J]udges are not like pigs, hunting for truffles buried in the administrative record,” the court noted. For that reason alone, the court found, the complaint would fail.

The Case is No. 25-1055-TJK.

Judge: Kelly, T.

Attorneys: Francesco Santora, pro se. Jenna Elizabeth Munnelly, U.S. Department of Justice, for Copyright Claims Board.

Companies: Copyright Claims Board

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