808.10 (I) (4) Publication of Underlying Works
The publication of a motion picture constitutes publication of all the underlying works used in the motion picture. Thus, a screenplay, musical score, or other underlying work are published to the extent that they are embodied in a published motion picture.
Maljack Productions Inc. v. UAV Corp., 964 F. Supp. 1416, 1421 (C.D. Cal. 1997) (stating that the publication of a film publishes all underlying works embodied in a film, including the screenplay).