The complaint

Polvino v. Robbins, No. 2:26-cv-12473 (C.D. Cal., Western Division), was filed October 25, 2026. The verified complaint is Document 1 and runs 106 pages, ending with Polvino's verification. The plaintiff is Marisa Polvino, a Los Angeles film producer, suing individually and derivatively as a member of OLF Productions, LLC, a California company named as a nominal defendant. The defendants are Anthony Robbins; Tony Robbins Productions, Inc.; Fox Corporation; MarVista Entertainment, LLC; Fox Entertainment Studios, LLC (Fox Studios); Kate Cohen; RAX Productions LLC; KCD Media, LLC; and Does 1 through 10. Polvino's counsel are Jacob J. Struck, who signed the complaint, and Katherine P. Deegan, both of Hunton Andrews Kurth LLP. The complaint demands a jury trial. Exhibit 1, the development financing agreement, is not publicly available. (Compl. pp. 1 to 2, 105 to 106; paras. 21 to 31, 70.)

The alleged venture

The complaint says the case arises from the collapse of a venture to bring Viktor Frankl's book Man's Search for Meaning to the screen as a feature film. It alleges that Polvino and Cohen began working on the project around 2016; that Polvino, Cohen, and a third member each hold one-third of OLF, which was formed in May 2022 and took an assignment of a predecessor company's option on the book's motion-picture rights from the author's estate; and that the venture raised and invested more than $1 million in development. It describes Robbins as an author and motivational speaker who worked with Polvino and Cohen on the project from about 2018 and alleges that, through Tony Robbins Productions, he contributed about $430,325 toward development between 2020 and 2024 under an arrangement it describes as a 50/50 joint venture. OLF and MarVista, which the complaint describes as a direct or indirect subsidiary of Fox Corporation, entered into a development financing agreement dated February 28, 2024 that, according to the complaint, set up a $300,000 development fund held in an OLF account and kept ownership of development materials in OLF unless and until MarVista exercised a studio option. (Compl. paras. 1 to 3, 21 to 22, 31, 48 to 51, 53 to 63, 70 to 76.)

The complaint alleges, on information and belief, that Cohen used more than $22,000 of development funds in 2024 for personal or unrelated expenses, and it alleges that in December 2024 she closed the OLF account and moved about $140,000 to an account that it alleges, on information and belief, is owned by KCD Media. It alleges that Cohen acknowledged that the agreement for the screenwriters' services had been entered into in the name of her company rather than OLF, and that Polvino was cut out of the talks to renew the option, which it says expired on or about October 25, 2024. After Polvino gave written notice in December 2024, it alleges, a MarVista business and legal affairs executive told her in January 2025 that "everything is on hold," while development went on without her. It alleges that a certificate of cancellation for OLF was filed in May 2025 stating that all members had approved dissolution, which Polvino says she never did, and that Fox Corporation, on MarVista's behalf, sent a July 2025 notice treating OLF as in breach because the option had lapsed. On information and belief, it alleges that Robbins, Tony Robbins Productions, or another Robbins company, alone or with a Cohen company, acquired the motion-picture rights, and it says Robbins publicly stated in January 2026 that he had acquired them and was making the film. It alleges that by July 2026 the film was financed and expected to enter production in fall 2026, with Cohen and Robbins among those identified as producers and Polvino excluded. (Compl. paras. 4, 12, 94 to 99, 104, 118, 126 to 135, 143, 147 to 148, 158 to 159.)

Twenty-one causes of action

The complaint pleads 21 causes of action, some by Polvino individually and most derivatively for OLF: (1) breach of contract against MarVista; (2) breach of the implied covenant of good faith and fair dealing under Cal. Corp. Code 17704.09 against Cohen; (3) breach of the implied covenant against MarVista; (4) fraud against Fox Corporation, Fox Studios, MarVista, and Cohen; (5) aiding and abetting fraud against MarVista, Fox Studios, and Fox Corporation; (6) breach of fiduciary duty against MarVista, Fox Studios, Fox Corporation, Robbins, Tony Robbins Productions, and Cohen; (7) aiding and abetting breach of fiduciary duty against MarVista, Fox Corporation, Fox Studios, Robbins, and Tony Robbins Productions; (8) breach of the duty of loyalty against Cohen; (9) aiding and abetting breach of the duty of loyalty against MarVista, Fox Studios, Fox Corporation, Robbins, and Tony Robbins Productions; (10) intentional interference with the development financing agreement against Robbins, Tony Robbins Productions, and Cohen; (11) intentional interference with prospective economic advantage, as to the new screenwriting agreement, against Cohen, MarVista, Fox Studios, and Fox Corporation; (12) intentional interference with prospective economic advantage, as to the option renewal, against Robbins, Tony Robbins Productions, and Cohen; (13) direct copyright infringement against Cohen and the Does; (14) contributory and (15) vicarious copyright infringement against MarVista, Fox Studios, and Fox Corporation; (16) civil theft under Cal. Penal Code 496(c) and (17) conversion against Cohen, RAX, KCD, and the Does; (18) civil conspiracy against Robbins, Tony Robbins Productions, Fox Corporation, Fox Studios, MarVista, and the Does; (19) unfair competition under Cal. Bus. & Prof. Code 17200 and (20) negligent misrepresentation against MarVista, Fox Studios, Fox Corporation, and Cohen; and (21) reinstatement of OLF to active status under Cal. Gov. Code 12261 against Cohen and the Does. Federal jurisdiction rests on the Copyright Act claims, with supplemental jurisdiction over the state-law claims. (Compl. paras. 18 to 19; pp. 47 to 103.)

The copyright counts

Count 13 alleges that in October 2025 Polvino submitted a copyright application on OLF's behalf covering four unpublished development works: a 2023 screenplay draft, a 39-page first act dated August 29, 2024, and two 2023 revised outlines. It says the 2024 first act was the deposit for Registration No. PAu 4-288-510, effective October 11, 2025, and that the 2023 draft (PAu 4-289-545) and the two outlines (PAu 4-288-819) were registered effective January 30, 2026. The complaint alleges that OLF owns the works, pointing to writer agreement terms that make the results of the writers' services works made for hire owned by OLF; that Cohen reproduced and distributed copies for the benefit of a party other than OLF without a license; and that the first act was sent to MarVista and Fox in September 2024 and used to approve the screenplay's direction and a new co-writer. On information and belief, it alleges that Cohen prepared or caused to be prepared later screenplay drafts and other derivative works using protected expression from the registered works and distributed them to MarVista, Fox, and others, and that the infringement continued after registration and was willful. It says Polvino has asked for the later drafts and has been unable to obtain them, and it pleads copying and substantial similarity on information and belief. (Compl. paras. 83, 85, 297 to 310.)

Count 14 alleges that, after Polvino's December 16, 2024 written notice, MarVista and Fox Corporation knowingly continued to give creative, legal, and financial support, including creative notes, to a Cohen company's derivative writing based on OLF-owned material, and that MarVista, Fox Studios, and Fox Corporation are each liable. Count 15 alleges that the same three entities had contractual and practical control over writer approval, script review, development, financing, and packaging, and a direct financial interest in the project through their development investment, a potential studio option, and a net-profit position. The complaint states that all three registrations became effective after the alleged infringement began, and on that basis it limits OLF's recovery on Count 14 to actual damages and infringer profits under 17 U.S.C. 504(b) and injunctive relief under 17 U.S.C. 502. (Compl. paras. 311 to 324.)

Relief sought

The prayer seeks a declaration that the defendants infringed the copyrights in the registered works; compensatory and consequential damages; treble damages under Cal. Penal Code 496(c); punitive damages; actual copyright damages and infringer profits under 17 U.S.C. 504(b); an order reinstating OLF to active status under Cal. Gov. Code 12261; preliminary and permanent injunctions against exploiting the registered works or substantially similar works and against further infringement; seizure and destruction of infringing materials; a sworn compliance report; an accounting of profits; a constructive trust over money and profits from the alleged misconduct and over all right, title, and interest in the book, the related option, acquisition, and motion-picture rights agreements, and the project and film, with an order directing the defendants to transfer them to OLF; attorneys' fees, costs, and interest; and statutory penalties. (Compl. pp. 103 to 105.)