A Not Quite Cinematic Lawsuit: Disney and Universal Studios File a Complaint Against Mid-journey

Hovey Williams July 7, 2025

Disney and Universal Studios filed a complaint against Midjourney on June 11, 2025, in the U.S. District Court for the Central District of California in Los Angeles. The suit is the latest among mounting, high-profile litigation brought against AI companies for copyright infringement. It also represents the first major suit by Hollywood media companies, as the industry continues to adapt AI and define limits for its use.

Disney and Universal’s complaint sets forth a black-and-white copyright infringement case: “Midjourney is the quintessential copyright free-rider and a bottomless pit of plagiarism.”

The complaint is replete with examples of uncanny recreations of classic characters from both companies. These examples capture how Midjourney’s Image Service platform generates vivid, colorful reproductions even in response to generic prompts that don’t name the characters outright.

From Plaintiffs’ perspective, Midjourney is clearly infringing on their intellectual property, both through its unauthorized use of Plaintiffs’ copyrighted works as input to train the AI, and through the outputs Midjourney’s platform generates for its customer base. And Plaintiffs further claim that Midjourney could easily stop this infringing activity through implementing preventative measures that recognize, reject, and screen for consumer input or the AI’s output of infringing content.

At moments, the reader might find themselves asking if any Hollywood writers lent a hand in drafting the complaint. Besides the beloved characters at the center of each respective studios’ universes, Plaintiffs bring in the who’s who on either side of the emerging debate over AI’s proper role in the artistic realm and its functional limits. On one side, Midjourney CEO David Holz is featured as emblematic of the very public and oftentimes brazen attitudes of big tech leaders towards claims of infringement, including in a 2022 interview in Forbes, where he allegedly claims that Midjourney grabs all that they can to feed the AI without ever seeking copyright owners’ consent. In stark contrast, research by Dr. Gary Marcus, a cognitive scientist and outspoken critic of overstatements by AI evangelists, is also featured. The Complaint details his Midjourney search prompts that generated images of myriad Disney and Universal characters without ever mentioning the characters or works in which they are featured.

The suit is also economically and culturally relevant for a number of reasons. It’s the first major engagement by Hollywood in front of a backdrop of AI lawsuits brought by major media companies, such as the New York Times against OpenAI. Whereas other companies are engaging tech companies alone, Disney and Universal have created  a unified front in the entertainment industry to seek a judgment that could impact how AI companies are allowed to train, market, and offer their services.

With the recent filing of the Complaint, it is unclear how this will play out in court. As one commentator has pointed out, unlike OpenAI or other major AI companies rising to the top of this industry, Midjourney is much smaller and has less access to funding than Silicon Valley heavyweights. This is something of a David-and-Goliath case and potentially a test run for how future court decisions could play out.

For the entertainment industry, the suit also highlights the dichotomous nature of how Hollywood is adapting to the emergence of AI, which has been equally destabilizing for corporations and the artists they employ. Not only do Plaintiffs face external threats to their intellectual property from platforms like Midjourney, but there has been considerable pushback against Hollywood’s own use of AI.  Beyond AI’s ability to create entire crowds or alter an actor’s appearance, there is mounting concern around its potential to lead to outright replacement of artists themselves, as in the case of creating AI replicas of background actors. How companies respond to pressure on either side is likely to dramatically reshape what it’s like to work in the industry, from stuntpeople to executives.

Hovey Williams
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