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The lawsuit brought against WWE and video game publisher by independent promoter Nathaniel Tatha-Nanandji, who promoted WCWA Wrestling in Arkansas was dismissed with prejudice on 9/10, PWInsider.com has confirmed. There had been a settlement conference set for 10/26.
In a ruling from District Judge David Clay Fowkes, the Court found that while there were copyrights in place for Tatha-Nanadji's work, there was "no copying of constituent elements of the work that are original" and that the plaintiff did not show direct copying in his filings. It also ruled that the defendants lacked "access to the copyrighted material."
The 30-page lawsuit from Tatha-Nanandji had alleged that WWE lifted intellectual material from his independent wrestling events for usage by The Bloodline on WWE programming and that he was "responsible for the creative direction, booking, staging, filming, and publishing of WCWA's events and audiovisual content" and that starting around August 2019, he developed a "distinctive, repeatable visual sequence for a faction in WCWA, known as Tier 1. The sequence was described as follows in the lawsuit:
a. The entrance, in-ring, or ringside action comes to a deliberate halt, and the Tier 1 members converge into a purposeful, hierarchical formation oriented toward the hard camera or primary broadcast camera, with the formation staged for frontal capture in a locked-off or minimally moving wide or mid-wide shot, ensuring all performers remain fully visible within the frame.
b. The group enters a brief but intentional pause, holding position while the camera framing remains fixed and centered, allowing audience attention to settle on the assembled faction and establishing the formation as a posed visual configuration rather than incidental movement.
c. A designated leader or cueing performer initiates the sequence by raising one arm upward as a visual cue, typically captured in a low-angle medium or medium-close framing that visually elevates the cueing performer within the composition while maintaining contextual visibility of supporting members.
d. Other members follow in staggered but coordinated succession, each raising one arm with a single finger extended, as the camera holds its position or slightly widens to preserve group coherence, allowing the synchronized gesture to complete fully within frame and emphasizing collective participation rather than individual motion.
e. In post-beatdown or domination contexts, the camera remains deliberately positioned, most commonly in a locked-off or minimally adjusted wide or mid-wide frontal angle from ringside or hard-camera orientation, to include the subdued opponent within the same frame as the assembled Tier 1 members. The opponent is visually subordinated within the composition, while the faction occupies the dominant, upright portion of the frame, ensuring that hierarchy, submission, and control are conveyed through spatial and camera-based composition rather than motion.
f. The sequence culminates in a sustained, static, camera-facing tableau, commonly framed symmetrically and held for a perceptible duration without camera movement, functioning as a recurring visual punctuation mark that conveys hierarchy, loyalty, submission, and collective authority, among related expressions of unified control, before the sequence is released and the scene transitions.
In their 9/19 ruling, the court stated, "The Court notes that the Tier 1 Sequence does not appear to be consistent across the Plaintiff’s exhibits as alleged in the Complaint. Defendants’ alleged infringing material is consistent in each iteration of the exhibits provided, and the Court finds that a reasonable person, reviewing the materials together, would only see the similarities amongst the Defendants’ clips but not the Plaintiff’s clips....In the Court’s opinion, the clips presented to establish substantial similarity have not met the standards required by the case law. For the foregoing reasons, the Court finds that the Plaintiff has failed to meet the requirements of access and substantial similarity as required for copyright infringement. As such, Plaintiff has failed to state a claim for direct copyright infringement."
Making it clear he was not claiming ownership over any single gesture or pose, but instead only the sequence listed, Tatha-Nanandji claimed that he created the sequence in April 2019 and had never abandoned the sequence event during times of "restructuring consistent with independent wrestling promotions." Tatha-Nanandji also listed two different videos from WCWA events that were copyrighted and provided proof of those copyrights. The events were titled "Monsters and Men: Xander Gold vs Brian Cage Oct '19" and "WCWA Rematch: Purge 1 Double D vs Dusty Gold." The copyrights were issued by the United States Copyright Office in September 2025.
In the lawsuit, Tatha-Nanandji alleged a never identified independent professional wrestler who performed for WCWA later appeared on WWE Smackdown and that the wrestler asked for WCWA footage that WWE scouting personnel could use "for review." Tatha-Nanandji stated he oversaw the preparation of the material and provided it to the wrestler, but within "weeks" the sequence he created for WCWA was now being used on WWE programming. Tatha-Nanandji also alleged a WWE "employee" attended a WCWA event in March 2019 and maintained contact with him through 2021. That WWE employee was not named in the lawsuit.
The court ruled on 9/19 that the plaintiffs had no proof that any of the defendants actually viewed the material, so it did not hold up to the scrutiny of the court and that the plaintiff was "asking the Court to make an unsupported leap in the access analysis and to infer access “based on conjecture and speculation.”
Tatha-Nanandji claimed, "Through these direct and indirect channels, including internal scouting review and publicly accessible WCWA content on platforms such as Facebook and YouTube, WWE and its affiliates had a reasonable opportunity to view, study, and copy the Tier 1 Audiovisual Sequence prior to and during Defendants' development and exploitation of substantially similar audiovisual content."
The lawsuit then alleged:
"On information and belief, beginning in or around September 2021, after Plaintiff had created and publicly used the Tier 1 Audiovisual Sequence, WWE introduced a visually and narratively similar ritualized audiovisual sequence for its "Bloodline" faction (the "Bloodline Sequence").
As deployed in WWE programming, the Bloodline Sequence consists of a coordinated audiovisual progression that includes, in combination:
a. Bloodline members aligning together in a deliberate, hierarchical formation oriented toward the primary broadcast camera;
b. A brief, intentional timing pause during which the formation is held;
c. A lead cue initiated by a designated member, followed by staggered but synchronized arm raises by the remaining members, each extending a single finger upward; and
d. A sustained, static, camera-facing tableau functioning as the climactic moment of acknowledgment within the segment."
The lawsuit alleged that WWE's "narrative framework" for their sequence is "a narrative function comparable to that performed by WCW's Tier1 Audiovisual Sequence" and provides photos of each version as evidence of their case and breaks down camera shots and "temporal architecture" that are "substantially similar" between the two.
The lawsuit also claimed that WWE has "licensed" the sequence to the WWE 2K video game series for the last several years.
Tatha-Nanandji alleged he first became aware of the similarity in January 2024 after reviewing and comparing the two and that he informed the defendants in October 2025 by letter that he was asserting WCWA's "longstanding common law trademark and trade dress rights" to the sequence. He alleges that despite notice of his claims, the defendants have continued their actions.
Tatha-Nanandji had demanded a jury trial and is seeking a declaration that the defendants have infringed on his copyrights from the WCWA material, a permanent injunction preventing them from continuing to do so - and to prevent the use of any footage featuring that material, the disablement of that allegedly infringing material from WWE 2K's video game properties, damages and any profits the defendants created by use of the allegedly infringing material proven at trial, an order requiring defendants to provide full accounting and records of revenue and profits made from the allegedly infringing material, the destruction of all allegedly infringing material, attorney's fees, a declaration that the defendant's "use of the Bloodline sequence and related audiovisual configurations" infringes on the plaintiffs' ownership and constitutes unfair competition, and an order requiring corrective advertising to dispel any confusion between the two works, among other requests.
Before the 9/19 dismissal, The two sides had been going back and forth in court as WWE argued that Tatha-Nahandji, doing business as WCWA Wrestling. claimed to have "creating a posing sequence" that has now been used by WWE talents, but has "inadequately alleged facts to support each claim." They argued that Tatha-Nahandji had not alleged the defendants had access to any of the wrestling videos with the gestures in question, therefore, he cannot establish that his work was indeed copied. They also argued that since there is no argument that there was underlying direct infringement, there's no way a secondary infringement claim can stand up to scrutiny before the Court. They also argued that his "tradedress claim" under The Lanham Act is also flawed, since Tatha-Nahandji alleged that the sequence is a "narrative function" and "thus, an expressive work." The defendants argued, "To avoid violating the First Amendment to the U.S. Constitution, a Lanham Act claim related to an expressive work can only be maintained if the alleged infringement has no artistic relevance to the defendants’ work, and it explicitly misleads as to the source or the content of the work by stating that the work is endorsed or affiliated with the plaintiff." They also argued that Tatha-Nahandji's claim of "unauthorized exploitation" of his audiovisual material is also preempted "because the claim targets an audiovisual work that falls within the subject matter of copyright, and it seeks to prevent unauthorized reproduction which is one of the exclusive rights under copyright."
Tatha-Nahandji had previously argued that WWE filed their response seven days later than allowed by the court and argued, "Defendants should not receive extra, non-automatic briefing time to recast Plaintiff’s claims into narrower theories he did not plead and then argue that those narrowed theories fail, especially where they have made no meaningful showing of cause for the additional briefing. Defendants waited twenty-one days to seek leave for a non-automatic reply and, in the proposed reply, introduced new accusations and new re-framings after the motion was already fully briefed as of right under Local Rule 7.2(b)."
On 5/26, WWE and the other defendants responded again, arguing:
"Plaintiff distorts copyright and trademark law beyond all recognition. Once Plaintiff’s meaningless, jargon-filled descriptions of his “Tier 1 Audiovisual Sequence” are brushed aside, it becomes clear that he is claiming exclusive rights over the simple act of a wrestler raising his arm with a “number 1” hand gesture or his championship belt in victory, followed by other wrestlers in the group doing the same. Of course, the “number 1” gesture and raising an award or prize are universal symbols used throughout the world to tout one’s accomplishments. If Plaintiff is permitted to monopolize such commonplace gestures and poses, it would put at risk athletes, sports fans and any other group of people who raise their fingers or awards in victory.
There are ample, well-settled grounds for dismissing Plaintiff’s claims. His copyright claim stumbles out of the gate, as he now admits that the unidentified WWE wrestler or employee who allegedly contacted him could not have passed on to WWE any WCWA matches with the Tier 1 Group Pose, because the pose did not even exist at the time. Plaintiff also concedes that the mere fact that the Tier 1 Group Pose was allegedly available online is insufficient to allege access, and his suggestion that someone at the WWE might have been monitoring his independent wrestling content over the years is based on legally insufficient speculation and conjecture. Plaintiff’s copyright claim also fails because he admits that individual poses and gestures are not protectable, and because there is nothing original or expressive about a leader striking a pose followed by other members of the group doing the same. That is a generic concept or idea, which are not protected by copyright. Nor is there any substantial similarity between Plaintiff’s Tier 1 Group Pose and the allegedly infringing WWE Bloodline poses. Plaintiff admits that the timing of his Tier 1 Group Pose is different from the WWE Bloodline poses, and that there are also substantial differences in the group configuration, camera angles, and lighting. No court has ever permitted a copyright infringement claim to proceed without substantial similarity of protectable expression, which is completely lacking here."
WWE and 2K had also argued that even if the WCWA footage was entitled to copyright protection, the lawsuit "must still be dismissed because there is no substantial similarities of protectable expression with the WWE Bloodline Group Poses." The court agreed.
Nathaniel Tatha-Nahandji's LinkedIn account cites the WCWA being formed in Springdale, Arkansas in 2012 and still being active. However, a website for the WCWA promotion has not been updated in years. The WCWA Facebook page was last updated in May 2021 while their YouTube page has not posted any new content since April 2021. A Google listing for the WCWA promotion lists its Springdale address as "permanently closed." The last event promoted as taking place by the promotion on their Twitter account was May 2021.
The lawsuit was officially dismissed with prejudice, which means it cannot be re-filed or resurrected before the court.
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