In the case of Fox Film Corporation v. Knowles et al., 1922, the U.S Supreme Court dealt with issues related to copyright law and its application to motion pictures. The plaintiff, Fox Film Corporation, claimed that it had exclusive rights over certain films due to a provision in the Copyright Act which granted such rights for "photoplays". However, defendants argued that these films did not qualify as photoplays under the act's definition because they were silent movies without accompanying music or dialogue. The lower court ruled in favor of defendants but on appeal, the Supreme Court reversed this decision. It held that silent movies indeed fell within scope of "photoplays" as defined by Copyright Act since they told stories through sequence of images and thus constituted dramatic compositions even without sound accompaniment.

In the dissenting opinion for FOX FILM CORPORATION v. KNOWLES et al., Justice Holmes disagreed with the majority's interpretation of copyright law and its application to this case. He argued that a film corporation should not be able to renew a copyright without obtaining permission from all parties involved in creating the original work, including actors and other contributors. According to him, allowing such renewal would unfairly benefit corporations at the expense of individual creators who contributed significantly to these works but might not have been adequately compensated or recognized for their contributions under existing contracts or agreements. This view reflects his broader belief in protecting individuals' rights against potential abuses by powerful entities like large corporations.