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Mitchell Silberberg & Knupp LLP Case 2:11-cv-10294-MMM-JCG Document 117 Filed 11/13/12 Page 32 of <strong>45</strong> Page ID #:2024 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 98. As described above, the so-called military-industrial complex is the nemesis in four of my films prior to 1991, when I had first contact with Mr. Morawski. In the case of both Aliens and Avatar, the corporate characters, backed up by military strength, were meant to evoke the historical precedent of big business opening up the colonial frontier in the Americas, using military force. The Weyland Yutani Corporation in Aliens and the RDA in Avatar are nothing but future versions of the Dutch West India Company and the Hudson Bay Company. And of course, the most vivid example of military force being used to open up a colonial frontier is the Conquistadors of Spain, who plundered and subjugated Central and South America with the superior technology of muskets, armor, cannons and horses. 99. In the Wind Warriors treatment, written in 1985-1988, the antagonist is also an industrialist backed up by private military strength. In that story, a powerful German industrialist, with his own private army of ground troops and aircraft, is searching the Amazon rainforest for an extremely valuable new metal of unknown origin. The industrialist believes that metal will be the key to untold new technologies. These ideas all preceded any contact that I had with Mr. Morawski. Valuable Minerals in an Alien Land 100. I conceived of the idea that the colonizers in Avatar (the RDA) obsessively pursue the mining of a valuable mineral because this is historically a significant motivation for colonization (gold, diamonds, oil). As described above, in Mother, one of the motivations for the Triworld Development Corporation to colonize the alien planet is to mine it for its resources. Both Mother and Avatar address the theme of humans trying to tame a new frontier on a distant virgin world. 32 DECLARATION OF JAMES CAMERON
Mitchell Silberberg & Knupp LLP Case 2:11-cv-10294-MMM-JCG Document 117 Filed 11/13/12 Page 33 of <strong>45</strong> Page ID #:2025 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 101. For the story to make sense, the mineral had to be rare and valuable enough for a corporation from Earth to spend significant amounts of money and go through all the trouble of setting up operations on a very distant moon. As in Wind Warriors, in Avatar, the bad guys are also after a metal that is the key to space flight (it makes possible the anti-matter drives in their ISVs (InterStellar Vehicles)) and the production of energy back on Earth. In Wind Warriors, the German industrialist predicts that the new metal will make possible space travel to the moon. 102. Reflecting my interest in physics, I decided to make the mineral a room-temperature superconductor that is highly valuable as an energy source − a fictional metal that I called “unobtanium.” I knew about the concept of a room- temperature superconductor from the 1970s, and since then wanted to incorporate that element into motion pictures. In science and engineering since the 1950s, the term “unobtainum” has been used jokingly to describe a material that is extremely rare or impossible, i.e., unobtainable. 103. I had the idea that there should be floating mountains, so I conceived that the nearby planet would have a strong magnetic field that would cause huge outcroppings of unobtanium to rip loose from the ground and to float, as a result of the repulsion of a superconductor from a magnetic field. It naturally followed from the fact that the mountains were filled with a room-temperature superconductor and suspended in extremely powerful electromagnetic fields (the “Flux Vortex”) that they would interfere with aircraft navigation systems. 104. In Avatar, the corporate bad guys are destroying the virgin rainforest of Pandora in order to get the new valuable metal. They will stop at nothing, including the use of high-tech military force against indigenous people armed only with bows and arrows, in order to get what they want. 33 DECLARATION OF JAMES CAMERON
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45-page sworn declaration - Business Insider

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