Context: On Wednesday, Sony Interactive Entertainment filed its opposition to Tencent’s motion to dimiss Sony’s copyright and trademark infringement complaint in the Northern District of California (October 17, 2025 games fray article). The original complaint already made it clear that Sony did not want to wait long until it would obtain injunctive relief against Tencent’s pre-release promotions and, ultimately, the publication of Light of Motiram, which Sony calls a Horizon Zero Dawn knockoff.
What’s new: Late on Thursday by local time, Sony has filed a motion for preliminary injunction (PI) with the United States District Court for the Northern District of California. Sony asks Judge Jacqueline Scott Corley, known by many gamers for her FTC v. Microsoft-Activision Blizzard decision (PI denial), to hold a hearing on November 20, 2025, apparently seeking a decision in late November or, more realistically, in December. The motion seeks to bar Tencent from using a red-haired tribal huntress character allegedly resembling Horizon‘s Aloy, other visuals, storyline elements, and a melody allegedly similar to two Horizon compositions: the main theme and City on the Mesa. To its motion, Sony attached multiple sworn declarations, including by Guerrilla Games Studio and Art Director Jan-Bart van Beek, the studio’s music lead Lucas van Tol, PlayStation Productions head Asad Qizilbash, and Sony brand IP director Matthew Kuykendall.
Direct impact: The motion was preceded by an exchange of letters in the summer in which Tencent’s counsel made it clear that his client was not going to make a cease-and-desist covenant as they deemed Sony’s then-forthcoming, now-filed motion meritless. Some of the arguments were found in Tencent’s motion to dismiss, and others will be raised and reinforced at this procedural stage. Tencent particularly argues that, given the scheduled release date of Light of Motiram (fourth quarter of 2027), Sony “cannot possibly hope to demonstrate the ‘immediate threatened
injury’ that is the prerequisite of a preliminary injunction” under the case law of the United States Court of Appeals for the Ninth Circuit, the regional appeals court for the U.S. West Coast, specifically citing to the 1988 ruling in Caribbean Marine Services Co. v. Baldridge. Sony, however, argues that its loss of control over its intellectual property is reason enough to grant a PI, and points (as it has previously done in this litigation) to numerous media reports and gamer comments on the internet that described Light of Motiram as a Horizon knock-off. It is difficult to predict the outcome, but
- Judge Corley may indeed be unpersuaded of the need for an injunction on the fast track and prefer to hold a full trial on the IP issues raised by Sony,
- some of Sony’s infringement allegations are clearly weaker than others, and
- a PI would have to be reasonably specific, but Light of Motiram is still under development, so the game itself and the related promotional materials are in flux, potentially raising difficult questions of compliance if Sony sought contempt-of-court sanctions against any modified material. Light of Motiram will see the light of day in one form or another. No PI could kill the project.
Wider ramifications: Sony argues that a PI is in the public interest so that companies investing in game development receive sufficient protection against knockoffs. In principle, that is a valid argument for IP enforcement, but as some of the absurdities surrounding Nintendo’s patent lawsuit against Palworld maker Pocketpair show (e.g., October 14, 2025 games fray article) it is also important not to discourage incremental creativity. The history of the games industry is not imaginable without inspiration, so courts must carefully draw a line between creative liberties and IP violations. This case may be a good vehicle for such clarification, possibly in the form of a mixed ruling where Sony would prevail on a limited part of its complaint, but not on all of it. In that case, however, Judge Corley may indeed prefer a full trial over a hastily-decided PI.
We will comment in more detail when Tencent has had the chance to oppose this motion, which would normally be in two weeks, though Tencent can seek an extension and may actually be granted one in light of the various allegations Sony has brought and the large number of exhibits attached to the PI motion. The November 20, 2025 hearing date that Sony requests may be wishful thinking in any event.
Here are some documents that the games industry, gamer community and games press may find interesting. First, the PI motion:
This is Sony’s cease-and-desist letter to Tencent:
Tencent’s “no way” response that also argued a PI motion of the kind Sony has now brought would be wasteful motion practice:
Jan-Bart van Beek’s declaration, which talks about how they created Horizon and how strongly they feel that Light of Motiram is a knockoff:
The declaration by Guerrilla music head Lucas van Tol about similarities in sound and melody:
The declaration by Sony’s Senior Vice President of Publishing, Studio Business Group and Head of PlayStation Productions, Asad Qizilbash:
The declaration by Sony brand IP director Matthew Kuykendall:
A declaration by a lawyer from the firm representing Sony (Orrick Herrington & Sutcliffe) that lists dozens of exhibits, most of which are promotional material (also including concept art) for Light of Motiram, and articles from the games press: