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==Backlash and decline== [[File:NestorStudios-Hollywood-1913.jpg|200px|thumb|left|[[Nestor Studios|Nestor Studio]], Hollywood's first movie studio, 1912]] Many independent filmmakers, who controlled from one-quarter to one-third of the domestic marketplace, responded to the creation of the MPPC by moving their operations to [[Hollywood, California|Hollywood]], whose distance from Edison's home base of [[New Jersey]] made it more difficult for the MPPC to enforce its patents.<ref>{{cite news |last= Edidin|first= Peter|date= August 21, 2005|title= La-La Land: The Origins|newspaper= [[The New York Times]]|page= 4.2 |quote= Los Angeles's distance from New York was also comforting to independent film producers, making it easier for them to avoid being harassed or sued by the Motion Picture Patents Company, AKA the Trust, which Thomas Edison helped create in 1909.}}</ref> The [[Ninth Circuit Court of Appeals]], which is headquartered in [[San Francisco]], [[California]], and covers the area, was averse to enforcing patent claims.<ref>e.g., {{cite court |litigants= Zan v. Mackenzie|vol= 80|reporter= F.|opinion= 732|court= 9th Cir.|date= 1897|url= https://archive.org/stream/gov.uscourts.f1.080/080.f1#page/n747/mode/2up}}, {{cite court |litigants= Germain v. Wilgus|vol= 67|reporter= F.|opinion= 597|court= 9th Cir.|date= 1895|url= https://archive.org/stream/gov.uscourts.f1.067/067.f1#page/n611/mode/2up}} and {{cite court |litigants= Johnson Co. v. Pac. Rolling Mills Co.|vol= 51|reporter= F.|opinion= 762|court= 9th Cir.|date= 1892|url= https://archive.org/stream/gov.uscourts.f1.051/051.f1#page/n773/mode/2up}}.</ref> [[Southern California]] was also chosen because of its beautiful year-round weather and varied countryside; its [[topography]], [[semi-arid]] climate and widespread [[irrigation]] gave its landscapes the ability to offer motion picture shooting scenes set in deserts, jungles and great mountains. Hollywood had one additional advantage: if a non-licensed studio was sued, it was only a hundred miles to "run for the border" and get out of the US to Mexico, where the trust's patents were not in effect and thus equipment could not be seized.{{citation needed|date=January 2017}} The reasons for the MPPC's decline are manifold. The first blow came in 1911 when Eastman Kodak modified its exclusive contract with the MPPC to allow Kodak, which led the industry in quality and price, to sell its raw film stock to unlicensed independents. The number of theaters exhibiting independent films grew by 33 percent within twelve months, to half of all houses. Another reason was the MPPC's overestimation of the efficiency of controlling the motion picture industry through patent litigation and the exclusion of independents from licensing. The slow process of using detectives to investigate patent infringements, and of obtaining injunctions against the infringers, was outpaced by the dynamic rise of new companies in diverse locations. Despite the rise in popularity of [[feature film]]s in 1912β1913 from independent producers and foreign imports, the MPPC was very reluctant to make the changes necessary to distribute such longer films. Edison, Biograph, Essanay, and Vitagraph did not release their first features until 1914, after dozens, if not hundreds, of feature films, had been released by independents.<ref>Per the ''American Film Institute Catalog of Motion Pictures'', 8 US features were released in 1912, 61 in 1913, and 354 in 1914.</ref> Patent royalties to the MPPC ended in September 1913 with the expiration of the last of the patents filed in the mid-1890s at the dawn of commercial film production and exhibition. Thus the MPPC lost the ability to control the American film industry through patent licensing and had to rely instead on its subsidiary, the [[General Film Company]], formed in 1910, which [[monopoly|monopolized]] film distribution in US. The outbreak of [[World War I]] in 1914 cut off most of the European market, which played a much more significant part of the revenue and profit for MPPC members than for the independents, which concentrated on [[Western (genre)|Westerns]] produced for a primarily US market. The end came with a federal court decision in ''[[United States v. Motion Picture Patents Co.]]'' on October 1, 1915,<ref>{{cite news |author=<!--Staff writer(s); no by-line.--> |title= Orders Movie Trust to be Broken Up|url= https://timesmachine.nytimes.com/timesmachine/1915/10/02/100179164.pdf|date= October 2, 1915|newspaper=[[The New York Times]] }}</ref> which ruled that the MPPC's acts went "far beyond what was necessary to protect the use of patents or the monopoly which went with them" and was, therefore, an illegal restraint of trade under the [[Sherman Antitrust Act]].<ref name="MPPC1915"/> An appellate court dismissed the MPPC's appeal, and officially terminated the company in 1918.
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