Baker v. Coates, 23-7483

Ralph W. Baker, Jr., proceeding pro se, sued Ta-Nehisi Coates and numerous parties, alleging copyright infringement of his book "Shock Exchange."
Baker claimed Coates copied the style and content of "Shock Exchange" in various works, including "The Water Dancer," "Between the World and Me," and other writings and films.
The district court dismissed Baker’s complaint for failure to state a claim, finding no substantial similarity between the works as a matter of law.
The magistrate judge's report recommending dismissal was adopted by the district court.
On appeal, Baker contested the dismissal and raised related procedural motions, including claims of unfair competition and service of process issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Substantial similarity (copyright)	Coates copied Baker's unique style and content from "Shock Exchange" across multiple works.	The works are not substantially similar in style, expression, or content.	No substantial similarity as a matter of law; complaint properly dismissed.
Comprehensive nonliteral similarity	The court failed to consider nonliteral similarities (overall structure/essence).	Assessed total concept and overall feel; no duplication of fundamental essence.	No comprehensive nonliteral similarity; district court’s approach affirmed.
Unfair competition & service of process	District court erred in dismissing claims against some defendants for insufficient service, and unfair competition.	Even if properly served, lack of substantial similarity defeats all such claims.	Lack of substantial similarity bars both copyright and unfair competition claims.
Procedural motions (motion to strike, contempt)	Sought to strike Apple’s brief and hold counsel in contempt for discovery issues.	No bad faith or actual deprivation of access to materials alleged.	Motions denied as meritless; Baker not deprived of meaningful opportunity to respond.

Feist Publ'ns, Inc. v. Rural Tel. Serv. Co., 499 U.S. 340 (defining elements of copyright infringement: ownership and copying of original elements)
Hamil Am. Inc. v. GFI, 193 F.3d 92 (setting forth the requirement of substantial similarity for copyright infringement)
Peter F. Gaito Architecture, LLC v. Simone Dev. Corp., 602 F.3d 57 (explaining standard for substantial similarity and dismissal at the pleading stage)
Williams v. Crichton, 84 F.3d 581 (describing factors for substantial similarity analysis)
Castle Rock Ent., Inc. v. Carol Publ’g Grp., Inc., 150 F.3d 132 (defining comprehensive nonliteral similarity test in copyright cases)
Warner Bros. Inc. v. Am. Broad. Cos., 720 F.2d 231 (noting unfair competition actions require likelihood of confusion rooted in substantial similarity)