By Peter Shimamoto ( January 24, 2019, 2:04 PM EST) -- A California Court of Appeal's November 2018 decision in an idea submission case, Sullivan v. Pure Flix Entertainment LLC,[1] misstates the applicable law and creates unwarranted potential exposure for studios. Under the reasoning set forth in Pure Flix, a studio could be liable to a party who pitched an idea for a motion picture to the studio, if the studio subsequently produces a motion picture that contains "core concepts" similar to those in the pitch, even though the studio was already aware of those concepts before the pitch, and even if the plot, themes, dialogue, mood, setting, pace, characters and sequence of events of the two works are significantly different. The Pure Flix decision is misguided and contrary to established law....