On Aug. 24, 2022 the Central District of California granted defendant's 12(b)(6) motion to dismiss in Hanagami v. Epic Games, 2022 WL 4007874 (C.D. Cal. Aug. 24, 2022), in which plaintiff Kyle Hanagami claimed that defendant Epic Games infringed his registered copyright in a choreographic work titled "How Long Choreography."

On Nov. 11, 2017, plaintiff, a Los Angeles-based choreographer and dance teacher, uploaded to YouTube a video of himself and others dancing to the song "How Long" by Charlie Puth. The five-minute video, which portrays five different groups of dancers performing the same series of movements, has received more than 36.5 million views as of this writing. On Feb. 20, 2021, plaintiff registered his copyright claim in the choreographic work fixed in the video with the U.S. Copyright Office.

While the Copyright Act expressly provides (in §102(a)(4)) for copyright protection for "pantomimes and choreographic works" fixed in a tangible medium of expression, neither term is defined in the Act. The court in Hanagami adopted the definition contained in Copyright Office Circular 52 (Copyright Registration of Choreography and Pantomime): "Choreography is the composition and arrangement of a related series of dance movements and patterns organized into a coherent whole." Circular 52 further notes that acceptable formats of fixation for choreographic works include traditional dance notation, such as Laban Notation and Benesh Dance Notation, video recordings of a performance, and textual descriptions, photographs, or drawings.