claim "'contain[ed] an 'extra element' [to] qualitatively 'distinguish[ }" it from rights provided under copyright law. Id. at 1535. But because the same act-Le., reproduction, distribution, or display-would trigger both a misappropriation and a copyright claim, and because the artist's allegation that she had been deprived of her sweat equity was "not qualitatively different from [a] . copyright infringement [claim]," the district court Held that the Copyright Act preempted the artist's misappropriation claim. Id. at 1535-36. 29 . Numerous cases concerning reproduction of photographs have held that the Copyright Act preempted state law misappropriation claims because the state law claims lacked an extra element. See, eg., Levine v. Landy, 832 F.Supp.2d 176, 191-92 (N.D.N.Y.2011) (<HOLDING>); CoStar Grp. Inc. v. LoopNet, Inc., 164
holding copyright act preempted photographers misappropriation claim when claim did not have extra element such as breach of fiduciary duty holding that breach of fiduciary duty claim was preempted by fehba holding misappropriation claim by real estate information service provider against website using services photographs was preempted by copyright act because claim had no extra element holding that utsa preempted a breach of fiduciary duty claim because the factual allegations supporting that claim involved only the misappropriation of  information holding that even if utah law recognized tort of misappropriation such a claim would be preempted by copyright act